Christine C. Deignan - Page 8

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          presented no evidence that would support a finding that there was           
          a conversion to a business purpose.  She has not demonstrated               
          that she held the property for a business purpose.                          
               Sixth, petitioner did not receive any income from the sale             
          of the house.  The only positive income she received in 1989 came           
          from her medical practice.  Finally, there was no regularity and            
          consistency in petitioner's activity regarding the property.                
          When petitioner filed for divorce, she stopped paying any of the            
          bills connected with the house.  This action is inconsistent with           
          her claim that the house was a business property that she                   
          intended to sell at a profit.  She resumed paying the bills and             
          eventually sold the property, but these actions were strictly in            
          compliance with the court order.  She made no sales efforts on              
          her own to indicate that she considered selling the house as a              
          business venture rather than a court-imposed obligation,                    
          obviously all in the nature of a salvage operation.                         
               Petitioner argues that the similarity of her case to Bassett           
          v. Commissioner, T.C. Memo. 1976-14, entitles her to an ordinary            
          loss deduction.  In Bassett, the taxpayers purchased a lot on               
          which to build a home.  Because of marital difficulties, the                
          couple decided to complete the house, but not as their personal             
          residence.  Before resuming construction, the husband consulted             
          with the architect and builder.  Although they modified the                 
          designs to cut costs as well as to give the house a wider                   
          commercial appeal, the taxpayers eventually sold the house at a             

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