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FINDINGS OF FACT
In 1964, David married Michelle Demetree (Michelle).
Between 1966 and 1973, David and Michelle had four children.
During the early 1970s, David, a licensed real estate broker,
opened and operated a property management firm, David Demetree
Associates - Realtors.
David and Michelle separated in 1979. In order to devote
most of his time to contentious divorce proceedings, in 1980
David closed his property management firm. In that year, he also
transferred 797 State Road 434 (797 property) to Arthur and Naomi
Demetree (Arthur and Naomi), his parents, 205 San Sebastian Court
to Walter Pemberton, his friend, and the Brahman Inn to Jeanette
Hinkle, his sister. In 1983, 1984, 1985, 1986, 1987, 1990, and
1991, Arthur and Naomi reported rental income relating to the 797
property, but in 1988, 1989, and 1992 David received the rental
income. In addition, David made the mortgage payments and
retained the rental income relating to 205 San Sebastian Court
until the lender foreclosed on the property. With respect to the
Brahman Inn, Demetree and Associates supervised the collection
and deposit of rents, while an onsite manager handled the day-to-
day operations (e.g., preparation of monthly summaries,
collection of rents, and payment of expenses).
In 1981, David and Michelle divorced. The following year
David married Deborah. Deborah had custody of a daughter from a
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