Barry E. Moore and Deborah E. Moore - Page 12




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          Clark Hill property.  They visited the property two weekends per            
          month beginning in mid-March (depending on the weather) and                 
          ending around Labor Day.  In addition, the family might visit the           
          property once or twice each winter, and Mr. Moore and his son               
          would fish off the dock one Saturday night each month during the            
          fall.  During the summer months, petitioners occasionally                   
          entertained visitors at the house.  Mr. Moore’s maintenance                 
          activities at the Lake Lanier property were similar to, but less            
          frequent than, his maintenance activities at the Clark Hill                 
          property.                                                                   
               The mortgage lender in connection with petitioners’ purchase           
          of the Lake Lanier property was SouthTrust Bank, N.A. (SouthTrust           
          Bank).6  On their 2000-02 Federal income tax returns, petitioners           
          claimed deductions for home mortgage and investment interest paid           
          to SouthTrust Bank as follows:                                              
               Year        Home Mortgage Interest      Investment Interest            
               2000                $36,219                  $5,647                    
               2001                42,437                   1,994                     
               2002                45,766                   --                        
               As in the case of the Clark Hill property, petitioners did             
          not list on their 2000-02 returns any deductions for maintenance            
          or other expenses associated with the Lake Lanier property.                 

               6  In its “Credit Offering Report” assessing the risk of               
          various loans to Ms. Moore, including the loan to purchase the              
          Lake Lanier property, that property, which was to serve as                  
          security for those loans, is consistently referred to as a                  
          “second residence”.                                                         






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