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residence. Following the 1969 bankruptcy, the residences were
titled in Ms. Walters' name alone.
During 1981 or 1982, petitioners purchased waterfront
property in Eastern Shores, an upscale section of North Miami
Beach, Florida. The property cost over $500,000 and consisted of
two lots. The house on the property had two stories, over 5,000
square feet, and five bedrooms. Petitioners built a tennis court
on the property. As she had done previously with other homes,
Ms. Walters employed domestic help whose wages were paid by Mr.
Gherman from an account other than the Joan Gherman No. 1
account.
Petitioners sold their former home to Shari and her husband
for $210,000. Approximately $90,000 to $100,000 of the purchase
price was paid by a note given to Ms. Walters. The funds Shari
used to purchase that house came from one or more of the accounts
in her name that Mr. Gherman controlled. None of the money in
the account came from Mr. Rance, and he did not know from where
it came.
Ms. Walters recognized that petitioners maintained a "nice"
lifestyle and that it was similar to that of many of the people
with whom they socialized. She believed that the improvements in
their standard of living were gradual over a number of years,
commensurate with the increase in Mr. Gherman's income, and that
there was no drastic change in their standard of living, inasmuch
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