James T. and Goldie L. Ryan - Page 4

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          problems, the Sopers could not pay the full price for the                   
          property.  On October 30, 1989, the Sopers agreed to pay                    
          petitioners $10,000 for an option to buy the Blue Lake property             
          (the option agreement).  The $10,000 payment was creditable                 
          toward the sale price; it was not refundable if the Sopers did              
          not buy the Blue Lake residence.  Thereafter, the Sopers                    
          landscaped the exterior, installed a dog run, and redecorated the           
          interior of the house by doing such things as hanging wallpaper.            
          Under the option agreement, the Sopers were responsible for all             
          maintenance on the house.  Petitioners did not make or pay for              
          any repairs on the Blue Lake property after October 30, 1989.               
          The Sopers agreed to obtain liability insurance for the                     
          residence.  After November 1, 1989, the Sopers made petitioners'            
          mortgage payments on the Blue Lake property to Home Federal Bank            
          and Beneficial Finance.  The payments to Home Federal Bank                  
          included reserves for all property taxes and liability insurance            
          on the property.  The Home Federal Bank mortgage required                   
          petitioners to maintain liability insurance on the Blue Lake                
          property.  Petitioners agreed to maintain fire insurance on the             
          residence.  The Sopers obtained renter's insurance for the Blue             
          Lake property.  They did not obtain title or hazard insurance for           
          the property.                                                               








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