-7-
example, he built two homes and bought cars for her, drove her
because she could not drive, drove her to visit her three sisters
when they were sick, supervised the funeral arrangements for each
of her three sisters, gave decedent insulin shots, and cared for
her during her final illness.
Decedent died on July 15, 1992. Petitioner was the only
person with her when she died.
3. The 1980 Transfer From Decedent to Petitioner
Sometime before April 1980, decedent listed 2,283 acres of
her land in Putnam County, Florida, for sale at $700 per acre.
Petitioner advised decedent to offer the property for sale at
that price.
On April 2, 1980, Terry Pacetti (Pacetti), a real estate
broker and investor from St. Augustine, contracted to buy the
Putnam County property for $700 per acre. Sometime between April
2 and August 1, 1980, Pacetti assigned the contract to Gerald
Thompson & Associates (the Thompson partnership), a partnership
that included partners who had extensive backgrounds in real
estate.
On April 21, 1980, decedent transferred to petitioner an
undivided one-half interest in 2,360 acres3 of the Putnam County
3 Although the deed states that decedent transferred 2,538.4
acres to petitioner, respondent agreed to value the property
(continued...)
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