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(hereinafter Lorna) filed their petitions, they resided in
Spokane, Washington.
In 1981, Paul, a graduate of Wesleyan University and Yale
University, worked for the New England Nonprofit Housing
Development Corp. In August 1981, Paul, along with Lorna and
their children, moved to Spokane, Washington, to aid his father
in developing several real estate properties and in handling his
father’s financial matters. Paul performed those services from
1981 until his father’s death in 1983.2 In 1984, Paul helped
settle his father’s estate. From 1981 to 1984, on account of the
services performed for his father and the settling of his
father’s estate, Paul withdrew funds from a joint account bearing
his name and the names of his father, his mother (Doris Kropp),
and Lorna. Paul treated the withdrawn funds as income on his tax
returns for those years. Paul and Lorna used the withdrawn funds
for their household’s living and medical expenses.
After the estate was settled, Doris Kropp owned several
tracts of undeveloped land, two health/sports facilities, a
condominium, and a brokerage account consisting mostly of
municipal bonds. Paul and his sister, Karen Harte (Mrs. Harte),
each received $600,000 from their father’s estate.
Soon after the death of her husband, Doris Kropp encountered
mental health problems and currently resides in a nursing home.
2 Paul’s father died in an automobile accident.
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