Estate of Edward Brockenbrough, Deceased, Sharon Brockenbrough, and Suntrust Bank, Coexecutors, and Sharon Brockenbrough - Page 6

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               Petitioners relied on friends to operate the antique store             
          when Mrs. Brockenbrough was away.  Initially, Ray Hawkins                   
          (Hawkins) operated the store when Mrs. Brockenbrough was away.              
          Petitioners did not pay Hawkins.  Later, petitioners hired                  
          Hawkins' wife to help run the business and to be a part-time                
          bookkeeper.                                                                 
               Before the years in issue, petitioners advertised their                
          antique shop in the Meriwether Indicator, the only newspaper in             
          the county at the time.                                                     
               Petitioners' antique business did not do well.  An antique             
          center opened in Warm Springs, Georgia, south of Gay, drawing               
          customers away.                                                             
               In February 1990, Gay's mayor and four city council members            
          decided that Gay needed a city hall.  Mr. Brockenbrough offered             
          to sell them the old bank building.  Petitioners had the building           
          appraised and submitted the result to the city council.  The city           
          council did not buy the building.                                           
               By 1990 or 1991,3 petitioners knew that they could not make            
          a profit from their antique store.  They kept it open part time             
          (3 to 5 days a week) until they could sell their merchandise.               
          They also left a sign in the window with their telephone number             
          and a message that if anyone saw anything that they liked in the            
          window to call petitioners at home, which was about 100 yards               


               3 The years in issue in this case are 1991 and 1992.                   




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