Robert R. Skorniak and Mary Skorniak - Page 10

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          residence as opposed to another.  See Stolk v. Commissioner, 40             
          T.C. 345, 351, 356 (1963), affd. 326 F.2d 760 (2d Cir. 1964).               
               Of paramount importance in determining whether petitioners             
          were using the 3405 house as their principal residence by January           
          31, 1992, is Mr. Skorniak's admission to Ms. Richards on June 1,            
          1993, that petitioners moved into the 3405 house in May or June             
          1992.  That admission is borne out by additional facts we have              
          found based on other portions of the record herein.  We have                
          found that there was construction work with respect to the inter-           
          ior of the 3405 house that was in progress during January 1992              
          and/or was not completed by January 31, 1992, including (1)                 
          sheetrocking, taping, texturing, and painting the walls and                 
          ceilings; (2) installing the flooring, including carpets and                
          tiles; and (3) installing soffits in the recreation room.  We               
          have also found that there was construction work with respect to            
          the exterior of the 3405 house that was not completed by January            
          31, 1992, including certain unspecified work relating to its                
          outside structure that was done after January 31, 1992, pouring             
          concrete for its front steps that was done during February 1992,            
          pouring concrete for its driveway that was done after February              
          1992, and installing its garage door that was done during April             
          or May 1992.                                                                
               We have also found that on February 20, 1992, Portland                 
          General Electric connected the electricity service, and on Febru-           





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