Sherburne M. Edmondson, Jr. and Diane L. Edmondson - Page 6

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          business. Neither petitioner nor Mr. Edmondson purchased a house            
          within 2 years after the date of sale.                                      
          Floyd Avenue House                                                          
               Sometime in 1988, Mr. Edmondson entered into an oral "equity           
          share" agreement with Wieland and Helen Emery von Behrens (friends          
          of the Edmondsons).  Pursuant to that agreement, the von Behrenses          
          purchased a house at 1393 Floyd Avenue, in Sunnyvale, California            
          (the Floyd Avenue house).  The von Behrenses held title to the              
          house, and were the only borrowers on a deed of trust.  Mr.                 
          Edmondson agreed to renovate the house in exchange for an eventual          
          equity interest in the property.3  This arrangement was made                
          because Mr. Edmondson could not qualify for a mortgage. Petitioner,         
          Mr. Edmondson, and their respective children lived in the house             
          during the year in issue.                                                   
          Petitioner's Present Circumstances                                          
               At the time of trial, petitioner supported herself and her             
          daughter,  working  as  an  administrative  assistant  for a                
          semiconductor firm.  She earned approximately $35,000 a year, and           
          paid yearly tuition of $5,000 for her daughter to attend private            
          school.  Petitioner also attended night school.                             
          The Edmondsons' 1988 Federal Income Tax Return                              
               The Edmondsons reported an adjusted gross income of $37,611.70         
          on their 1988 Federal income tax return. Two Schedules C were               

               3    There is no additional evidence in the record regarding           
          this arrangement.                                                           




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