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years before he retired on August 8, 1995, Mr. Brockenbrough flew
international routes to Europe which required him to be away from
home about 12 days a month. He and his wife vacationed about 1
month each year in Florida, where they had a boat.
Mr. Brockenbrough's wages from Delta were $228,102 in 1991,
$251,822 in 1992, and $47,612 in 1996, the year after he retired.
Mr. Brockenbrough also received a lump sum distribution in 1995
of about $750,000.
2. Sharon Brockenbrough
Petitioner Sharon Brockenbrough (Mrs. Brockenbrough) was a
flight attendant on Delta's flights to Europe from about 1982 to
the date of trial. Around the time petitioners started their
antique activity, Mrs. Brockenbrough typically left Atlanta on
Friday nights and returned on Sunday nights.
3. Petitioners' Farm
Petitioners wanted to live in a farming area near Atlanta,
Georgia, and be able to generate some income after they retired
from Delta. In 1986, they bought a 52-acre farm with a house on
it in Gay, Georgia, about an hour's drive south of Atlanta. They
paid for the farm by assuming about a $130,000 balance on the
seller’s mortgage. Petitioners did not buy the farm to speculate
on land values.
B. Olde Bank Antiques
There were three or four antique stores in the Gay, Georgia,
area in the mid-1980's. Mr. Brockenbrough discussed starting an
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