Eloise Gaddy Joens - Page 8

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            Emmens held their wedding at the property and lived there for a                           
            period of time.  When petitioner and Emmens decided to move, they                         
            put the Flamango Lakes property up for sale.  The purchase of a                           
            new residence, however, was not contingent on the sale of the                             
            Flamango Lakes property.  The property was not sold and was                               
            subsequently converted into rental property in June 1984.                                 
            Petitioner maintained the monthly rental income records                                   
            pertaining to the Flamango Lakes property.                                                
                  Petitioner and Emmens moved from the Flamango Lakes property                        
            in 1984 to a house in Antiquers Aerodrome (the Aerodrome                                  
            property), a development in Delray Beach in which all the homes                           
            have access to a private airstrip.  The Aerodrome property, which                         
            was purchased for $250,000 in cash, had four bedrooms, three                              
            baths, a pool, and a hangar in the backyard.  The record owner of                         
            the Aerodrome property, however, was Palm Beach Property                                  
            Investments, Inc. (Palm Beach Property Investments), which was                            
            incorporated by Kadyszewski.  The corporation was used to conceal                         
            the ownership of the Aerodrome property.  Although petitioner and                         
            Emmens lived at this property, they did not pay rent to Palm                              
            Beach Property Investments.  Further, petitioner was present at a                         
            meeting of the Antiquers Aerodrome homeowner's board where the                            
            titling of the property in a corporate name was discussed.                                
            Petitioner and Emmens lived at the Aerodrome property for 1 year,                         
            and then moved to a residence on Gardenia Street (the Gardenia                            





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