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pay or reimburse petitioner for traveling expenses. Most of the
checks drawn on the accounts were prepared and signed by Ms.
Gutierrez, but it appears that certain checks, although signed by
Ms. Gutierrez, were actually prepared by someone else. Some
checks, including checks made payable to cash, were signed by
petitioner.
In 1993, CWS purchased 94 acres (approximate area, including
dry land and a lake) in Madison, Florida, for $65,5503 (the
Mystic Lake property or the property). When purchased, the
Mystic Lake property contained four dilapidated structures that
previously had been used as a motel.4 Petitioner and Ms.
Gutierrez, who were then living in Georgia, intended to construct
a personal residence in the likeness of a medieval castle on the
property. They renovated three of the four existing structures
to a condition that allowed each to be used as a residence by
petitioner, Ms. Gutierrez, and other members of their family
while the “castle” residence was being built. Renovations on the
fourth structure were completed by early 1995. As of March 1995,
3 There is some question as to whether the purchase price
was $65,000, as indicated by each party’s expert, or $65,550, as
stipulated by the parties. Because the parties have stipulated
to the adjusted basis of the property, the discrepancy is of no
significance.
4 Apparently these structures were in such poor condition
that the local real estate assessment authority had removed them
from the real estate tax rolls.
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