George W. and Margaret L. Gagnon - Page 4

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               In addition, petitioner bought some bushes and trees from              
          wholesale dealers, and held them for sale on the Sixth Street               
          property while they matured.  If someone wanted to buy a tree or            
          bush during the week, he or she would tell a neighbor of                    
          petitioner, take it, and petitioner would send the buyer a bill.            
          The record does not indicate the specifics of this aspect of the            
          nursery activity.                                                           
               Petitioners drove to Long Beach virtually every weekend and            
          holiday.  They substantially renovated the cottage on the Oregon            
          Street property in which they stayed.  While Mr. Gagnon was                 
          occupied on the weekends with the nursery activity at least                 
          during the bulb potting season, Mrs. Gagnon apparently was not              
          active with the nursery activity.                                           
               The following items of income and expenses have been                   
          stipulated as incurred with respect to the Long Beach properties            
          and the nursery activity:                                                   



















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