-6-
account, and 1 money market savings account over which petitioner
did not have signature authority at First Union National Bank of
Florida. These accounts totaled $1,102,944.03.
Before 1979, Georgia-Pacific acquired Hudson and assumed the
timber lease on decedent's property. In 1979, Georgia-Pacific
bought 4,200 acres of the property and released the remaining
acres from the lease. Georgia-Pacific paid decedent more than $1
million for the 4,200 acres in 1979. Decedent gave $283,000 to
petitioner from the proceeds of the sale. After the sale,
decedent owned 2,360 acres in Putnam County (the Putnam County
property) and 2,315 acres in Clay County (the Clay County
property).2
Petitioner hired workers to help him harvest timber from the
released 4,675 acres. Petitioner divided the profits equally
with decedent.
2. Personal Relationship Between Petitioner and Decedent
Petitioner and decedent had a very close personal
relationship. Petitioner loved decedent as if she were his
mother and she loved him as if he were her son. He took care of
her personal matters with no expectation of compensation. For
2 Petitioner testified that decedent owned about 2,300 acres
in Putnam County and about 2,200 acres in Clay County after she
sold property to Georgia-Pacific. The parties agree, however,
that decedent transferred one-half interests in 2,360 acres in
Putnam County and 2,315 acres in Clay County to petitioner.
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