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all of Mr. Monsour’s assets. That agreement provided that
petitioner was to receive (1) 10 percent of Mr. Monsour’s assets
in the event that she and he were to divorce prior to a stated
time not disclosed by the record and (2) a percentage of Mr.
Monsour’s assets not disclosed by the record in excess of 10
percent if she and he were to remain married after such stated
time and were to have children. Petitioner and Mr. Monsour had
three children for whose care she was principally responsible
during the taxable years at issue.
Mr. Monsour’s assets listed in the prenuptial agreement and
Mr. Monsour’s assets that he acquired either alone or with others
excluding petitioner after he married her included the following
assets acquired in the years indicated.
In 1971, Mr. Monsour bought a house situated on 68 acres of
land known as Open Heart located in the mountains in Fairfield
Township, Pennsylvania (Open Heart property).
In 1973, Mr. Monsour and his three brothers, Robert Monsour,
Roy Monsour, and Howard Monsour (collectively, Mr. Monsour’s
brothers), formed a partnership known as Monsour Gator Groves
(Monsour Gator Groves), which invested in a 290-acre orange grove
located near Sarasota, Florida (Sarasota). In 1989, they sold
that partnership.
In 1974, Mr. Monsour and Mr. Monsour’s brothers formed a
partnership known as Laurel Valley Farms, which invested in
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