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petitioner's daughter, who testified at trial on behalf of
petitioner.
Although petitioner was not involved in the day-to-day
conduct of the real estate business, over the years she was a
party to many transactions in the acquisition and sales of
property and, in several instances, in instituting legal actions
with Mr. Gurr in connection with land titles. Several tracts of
land were acquired in her name alone and others jointly with Mr.
Gurr. The Court is satisfied from the evidence that petitioner's
name on these deeds was not for nominal purposes. For example,
in 1991, Mr. Gurr filed an individual petition for relief under
Chapter 11 of the Bankruptcy Code. Prior to institution of the
proceeding, he arranged with petitioner to have certain real
estate transferred to her in order that such property would be
beyond the reach of his creditors.5 Petitioner knew and
understood that to be the purpose of the transfer. During the
course of the bankruptcy proceeding, Mr. Gurr petitioned the
court for the sale of a certain tract of real estate in which
petitioner owned a one-half interest. That sale was a $455,000
transaction. Petitioner consented to the sale on the condition
that her interest in the sales proceeds be protected. She also
consented to the use of some of the proceeds for payment of
5 There is no indication in the record that Mr. Gurr's
creditors challenged the validity of the transfer.
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