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Andrade's and Garrabrant's testimony was consistent with that
testimony.
d. End of VTC's Construction Activities
Respondent contends that Ann Van Tine did not provide
services beyond the early 1970's because, according to
respondent, that is when VTC stopped its construction activities.
Decedent was semiretired in 1981 but VTC built homes and managed
apartments in the early 1980's. On December 15, 1980, decedent
told an IRS representative that he had some condominiums that
would not be completed until 1981 or 1982. On September 20,
1982, Ebaugh wrote a note evaluating decedent's medical condition
in which she said: "His daughter is going to take a more active
role in helping * * * business." Despite this, we believe Ann
Van Tine did not provide a significant service to VTC after 1982.
She moved from 7 Diamonte Lane to Big Bear around 1980. She
began to work full time for Ebaugh in 1982. There is no evidence
that VTC constructed anything after the Garrabrant home in 1980.
e. Ann Van Tine's Other Activities
Respondent contends that Ann Van Tine could not have
provided a significant service to VTC because she had many other
activities including growing bonsai trees, keeping German
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