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3. Petitioners’ Care for Mr. Stern From 1987 to 1992
Mr. Stern lived with petitioners in Indianapolis for 5
years, from 1987 until he died in 1992. Mr. Stern paid no rent
during the time that he lived in petitioners’ home. Petitioners
moved Mr. Stern into their guest bedroom, which had a radio,
television, and telephone. Petitioners also provided Mr. Stern a
home office with a desk, typewriter, writing materials, and a
locking fireproof file cabinet. Mr. Stern needed the office
because he had numerous investments and bank accounts.
Mr. Stern had full use of petitioners’ house. For example,
in addition to using the furnished bedroom and office, Mr. Stern
kept boxes containing his business records in one bay of
petitioners’ two-car garage and kept his automobile in the other
bay.
Petitioner bought clothing for Mr. Stern, including shoes,
socks, hats, gloves, a suit, two dress shirts, two ties, a
topcoat, sweaters, insulated pants and shirts, a warm-up suit,
pajamas, a robe, slippers, and underwear.
During the 5 years that Mr. Stern lived in petitioners’
home, petitioner bought all the personal items he required,
including shaving gel, razor and blades, aftershave lotion,
denture cleaning tablets, denture liners, nail clippers,
deodorant, shampoo, hair dressing, brushes, ear wax remover,
tissues, first aid items, foot powder, vitamins, milk of
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