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We will analyze the three documents relied upon by
petitioners. First, however, we wish to state our view of the
relationship between Bell and decedent: Bell and decedent met in
1947 and developed a close, personal relationship. Following the
death of decedent’s wife in 1963, they resided together in
decedent’s house. They had a loving relationship, traveled
together as husband and wife, and, together, cared for decedent’s
invalid daughter. Bell supervised decedent’s household.
Decedent entrusted Bell with access to his wealth and gave her
power to make decisions with respect to his medical care. During
the years here in question, their relationship resembled that of
a successful marriage and not an employment relationship.
B. The Agreement
We have set forth the pertinent provisions of the Agreement
in our findings. Although the Agreement describes both past and
future services and, thus, is consistent with an employment
relationship, we believe that the Agreement signifies decedent’s
desire to protect Bell from a will contest following decedent’s
death. Petitioner Kyle C. Brooks and other witnesses testified
that decedent was concerned that a will contest would follow his
death. Decedent told Betty C. Bryan, one of the witnesses to the
Agreement, that he wished to be sure that Bell was taken care of.
Moreover, the past and future services referred to in the
Agreement are consistent with the loving, marriagelike
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