Claudia F. Walker - Page 3

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               At the time of their divorce, petitioner’s and Mr. Walker’s            
          marital estate was worth several million dollars.  Included in              
          the marital estate was a piece of real property (Happy Valley               
          property) located next to petitioner’s and Mr. Walker’s home in             
          Clackamas County, Oregon, in which petitioner and Mr. Walker                
          jointly owned a 50-percent interest.  The other 50-percent                  
          interest in the Happy Valley property had been conveyed to a                
          trust for the benefit of petitioner and Mr. Walker’s children and           
          grandchildren (Walker Family Irrevocable Trust).                            
               The marital settlement agreement that was entered into by              
          petitioner and Mr. Walker severed their joint ownership in the              
          Happy Valley property and conveyed separate 25-percent interests            
          to each of them.  In accordance with the terms of the marital               
          settlement agreement and pursuant to a bargain and sale deed                
          signed and dated by petitioner and notarized on October 10, 1996,           
          and signed and dated by Mr. Walker and notarized on October 17,             
          1996, petitioner and Mr. Walker, as grantors, conveyed to                   
          petitioner, as grantee, one-half of their previously jointly                
          owned 50-percent interest in the Happy Valley property.  The                
          stated consideration for this conveyance was the Stipulated                 
          Judgment of Dissolution of Marriage (divorce decree) entered in             
          Clackamas County (Oregon) Circuit Court Case No. 96 04 504,                 
          Walker v. Walker.  Neither the marital settlement agreement nor             








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