Bryan J. and Christine N. Baugh - Page 5

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          during 1988.  Petitioners generally rented apartments, trailers,            
          or houses while they were working at various power plants.  In              
          early 1991, petitioners purchased a trailer that they moved from            
          job to job so they would not have to worry about finding                    
          accommodations at each job site.  The trailer also provided an              
          easier way to move petitioners’ personal belongings from job site           
          to job site.  Until mid-1990, petitioners stayed with                       
          Mrs. Baugh’s parents on Hickory Ridge Drive (Hickory Ridge) in              
          Port Clinton when petitioners returned to Port Clinton between              
          jobs.  For convenience in receiving their mail, petitioners used            
          the Hickory Ridge address when they were on work assignments away           
          from Port Clinton.  Petitioners maintained their voter and car              
          registrations and their driver’s licenses in Port Clinton, using            
          the Hickory Ridge address.                                                  
               In April 1990, petitioners purchased a duplex located at 414           
          and 414-1/2 Monroe Street (Monroe) in Port Clinton.  Petitioners            
          wanted to purchase property so they would not have to stay with             
          Mrs. Baugh’s parents when they were in Port Clinton and so they             
          would have a place to store furniture.  Petitioners chose to                
          purchase a duplex because they knew they would be away from Port            
          Clinton on work assignments and having a tenant living on the               
          premises would provide security.   Petitioners hired Jack Bradley           
          Realty to manage the Monroe Street property.  Petitioners rented            
          414 Monroe beginning in mid-1990 and continuing throughout 1992,            
          except for 2 months in 1992.  Petitioners did not begin to rent             
          414-1/2 Monroe until mid-1992.  Petitioners derived no income               



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