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previous marriage, and in 1983, David was awarded sole custody of
his four children. Although they struggled financially on
Deborah’s salary as a full-time insurance adjuster, David stayed
at home to care for the five children and perform domestic
duties.
Prior to and during the years in issue, David had a close
relationship with Arthur, Naomi, and Ms. Hinkle. David relied
heavily on their generosity to supplement Deborah’s salary.
Arthur and Naomi regularly gave David and his family large gifts.
They gave two homes to David, $900,000 in trust for David’s
children, annual $10,000 gifts to petitioners and each of David’s
children, automobiles to each of petitioners’ children, and
weekly gifts of cash and food to petitioners. They also made
substantial loans to David documented with numerous promissory
notes. Upon David’s failure to repay some of these loans, Arthur
and Naomi obtained a $300,000 judgment against him. Yet they
continued to transfer significant amounts of money to
petitioners. In addition, Ms. Hinkle lent David funds from the
Brahman Inn business account. She documented these loans with
promissory notes and upon David’s failure to repay some of these
loans obtained a judgment against him.
From the early 1970s through his death in 1991, Arthur, a
successful real estate developer and broker, operated Demetree
and Associates, a commercial property management sole
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