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for our consideration is set forth below with separate
background and discussion.
General Background
The parties have stipulated some of the facts. When the
petitions were filed, Briggs resided in Alford, Florida, and the
Morrises were married and resided in Panama City, Florida.
In 1982, Briggs and the Morrises started a multi-million-
dollar real estate construction business known as the Towers
Group. The Towers Group ultimately comprised nine corporations,
with activities ranging from real estate management to town
house construction and sales. Two of the Towers Group
corporations were: (1) Towers Construction Co. of Panama City,
Inc. (Towers Construction), which was in the construction
business and eventually constructed town house units in a Panama
City Beach, Florida, project known as the Gulf Highlands Beach
Resort (Gulf Highlands); and (2) Towers Development Co. of
Panama City, Inc. (Towers Development), which was in the
development business and eventually developed the Gulf Highlands
project.
For the years in issue, Sandra Morris (Mrs. Morris) and
Briggs each owned 50 percent of the stock of Towers Construction
and Towers Development.2 Briggs was president of Towers
Construction and Towers Development for the years in issue.
2 Mr. Morris was not a shareholder of any of the
corporations in the Towers Group, having placed all his interests
in his wife’s name to avoid his creditors.
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