Orneal and Martha Kooyers, et al. - Page 5

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          as chief executive officer, and Mrs. Kooyers served as a teacher            
          and missionary.                                                             
               Petitioners’ daughter Leah graduated from college in 1978              
          and married Doug Heidema, a son of other missionaries.  Leah and            
          Doug settled in Ambunti and assisted petitioners with their                 
          missionary activities.  Petitioners also sought and trained New             
          Guinea nationals to serve as leaders in the mission activities of           
          P.I. Ministries.  Eventually, those nationals conducted a large             
          portion of the mission’s activities.                                        
               Over the years, the activities of P.I. Ministries greatly              
          contributed to the development of the Sepik area.  With funds               
          provided by the U.S. Agency for International Development, P.I.             
          Ministries constructed (i) a large joinery to construct canoes,             
          trusses for buildings, school furniture, and water tanks, (ii)              
          new wards for the Ambunti clinic, and (iii) rain-collection water           
          systems for 165 villages.  More recently, P.I. Ministries has               
          supplied villages with medicines and assisted in training                   
          orderlies to provide basic medical treatment.                               
          B.   Creation of the OMK Trusts                                             
               Petitioners were frugal, made wise investments, and were               
          provided retirement benefits by P.I. Ministries.  Consequently,             
          by 1995, they had accumulated substantial savings.  Petitioners             
          continued to live a very modest lifestyle, however, even after              








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