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FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The first and second stipulations of facts and the attached
exhibits are incorporated herein by this reference. Petitioners
resided in Atherton, California, when their petitions were filed.
I. Background
Petitioner Justin M. Jacobs, Jr. (Jacobs) is a real estate
developer and licensed attorney. Since the late 1960's, Jacobs
has primarily worked in the real estate development business,
having stopped the active practice of law in 1970. Jacobs has
principally built office buildings for the high-tech industry in
the Silicon Valley and San Francisco Bay areas of California. As
of the date of trial in these cases, Jacobs had constructed
approximately 45 buildings.
Jacobs has also had an interest in historic buildings.
Consistent with this, he has been involved in the restoration and
subsequent sale of historic properties. Jacobs has renovated
several houses in California, including a large Victorian-era
house in Atherton, California, and a 33,000-square foot mansion
situated on 6 acres in Hillsborough, California. He has also
restored an 11th-century chateau located in Loiret, France, and a
five-story townhouse on Sutton Square overlooking the East River
in New York City.
Jacobs has also been involved in the antiques business.
Sometime prior to May 1981, Jacobs decided to purchase a large
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