Maureen Monsour - Page 4

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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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