William P. Short, Jr. and Mary E. Short - Page 3

                                         -3-                                          
          claimed title to the disputed land. Petitioners never paid real             
          estate taxes on the disputed land.                                          
          The 1988 Gift Land                                                          
               At issue is petitioners' ostensible 1988 contribution of               
          approximately 8-acres of the disputed land (the 1988 gift land) to          
          the State of Delaware. At the time of the purported donation, the           
          State of Delaware considered the disputed land, including the 1988          
          gift land, part of the Delaware Seashore State Park.                        
               Petitioners' claim of title to the 1988 gift land is based on          
          a quitclaim deed that petitioner purchased on August 16, 1982, for          
          $100 (the 1982 quitclaim deed) from J. Bennett Hill, a purported            
          heir to one-fourth of the property interest of a Colonel William D.         
          Waples.  Any interest obtained by petitioner apparently derived             
          from an 1839 recorded three-fourths tenants-in-common interest held         
          by Colonel Waples and two other individuals.  The 1839 title was            
          the last title interest recorded with respect to the 1988 gift              
          land; and, the chain of title that followed this interest is                
          uncertain and uncorroborated. It appears that Colonel Waples'               
          interest in the 1988 gift land was likely abandoned, and                    
          subsequently acquired by the State of Delaware in the early 1900's.         
               In addition to claiming title to the 1988 gift land under the          
          1982 quitclaim deed, petitioners also claimed title to the land by          
          adverse possession.                                                         








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