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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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