S. Robert Davis - Page 11




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               1.   Mr. Davis' Gifts of Real Property to Charities                    
                    a.   Brown Road Property                                          
               On or about April 21, 1971, Davis Co. purchased the Brown              
          Road property.  In 1974, Davis Co. liquidated and distributed its           
          assets, including the Brown Road property, to Mr. Davis.                    
               Paul Eddy (Mr. Eddy), Mr. Davis' brother-in-law, was a                 
          founding member of, and a deacon at, the Maranatha Baptist Church           
          (MBC).  Mr. Davis was not a member of the MBC.  During 1976, Mr.            
          Eddy solicited a gift from Mr. Davis to the MBC.  On or about               
          December 22, 1976, Mr. Davis donated the Brown Road property to             
          the MBC.                                                                    
               In response to Mr. Eddy's solicitation of Mr. Davis'                   
          donation of the Brown Road property, the MBC's pastor (Pastor               
          Brock) offered a tuition waiver to Mr. Eddy for his children                
          attending a school operated by the MBC.  Mr. Eddy declined the              
          offer because he felt that accepting it was improper for a deacon           
          of the church.                                                              
               Mr. Eddy suggested to Pastor Brock that he make the offer to           
          Judy Mascari (Ms. Mascari) instead.  Ms. Mascari is Mr. Eddy's              
          sister-in-law and Mr. Davis' sister.  Ms. Mascari and her family            
          were members of the MBC, and during 1976, some of Ms. Mascari's             
          children (Mr. Davis' nieces and nephews) attended the school                
          operated by the MBC.  The offer was made to Ms. Mascari, and she            
          accepted it.                                                                





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