Gary B. and Kathleen Mitchell - Page 4

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          Matthew used the Fairway residence until late May 1990 when he              
          moved to the townhouse and used it until he purchased a new home            
          during July 1990.                                                           
               During the spring of 1990 petitioners were packing their               
          personal belongings, planning their move, and arranging for sale            
          of their interim residence (townhouse).  The townhouse and the              
          Fairway residence were only a few blocks apart.  Throughout the             
          period concluding on June 21, 1990, petitioners moved items into            
          the Fairway residence, including lamps, boxes of clothing,                  
          furniture, and household items.  The townhouse was placed on the            
          market without a broker by means of a "For Sale" sign and                   
          petitioner wife personally undertook the effort to sell it.  Due            
          in part to the advice of a real estate developer, petitioners               
          left some of their furniture in the townhouse and heated and air-           
          conditioned it during the period it was for sale to improve the             
          chances of sale.                                                            
               On June 20, 1990, petitioners, in order to complete the                
          process of moving into the Fairway residence, hired movers to               
          handle some heavy items, including a gun safe, large china                  
          closet, large boxes of books, and other heavy items that they               
          were unable to move themselves.  As of June 20, 1990 petitioners            
          had moved all of their belongings into the Fairway residence,               
          leaving some of their furniture at the townhouse.  On June 20,              
          1990, the U.S. Postal Service effected petitioners' change of               
          mailing address from the townhouse to the Fairway residence.                




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