3
Petitioner operated the business of Art Rep Services throughout
the taxable years in issue.
Petitioner purchased a single family home in St. Paul,
Minnesota, sometime in the early 1980's. Petitioner originally
intended to renovate this house and sell it, recognizing
appreciation due to the market combined with his improvements.
Instead, petitioner rented it to a tenant within 3 months of
purchase.
In 1984, petitioner purchased a second property, a duplex,
in Minneapolis, Minnesota, on Pillsbury Avenue (Pillsbury
property). Petitioner purchased this property with the intention
of renting it while waiting for it to appreciate in value.
Petitioner rented the top floor to tenants and moved into the
first floor.
In 1990, petitioners married. Petitioner Nancy Nadeau owned
a town house (Eden Prairie property) which she purchased in 1988.
Beginning in 1990 petitioners received rental income from the
Eden Prairie property through Nadeau Rentals.
In 1990, petitioners sold the Pillsbury property recognizing
a gain of approximately $27,000, and purchased another duplex in
Minneapolis, Minnesota, on Lyndale Avenue (Lyndale property)
anticipating it would appreciate in value. Petitioners moved
into one of the two units and rented the other. At the end of
1990, petitioners owned three properties, the St. Paul, Eden
Prairie, and Lyndale properties.
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