Robert R. Skorniak and Mary Skorniak - Page 12

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          the laundry facilities at the 3395 residence; and (3) petitioners           
          ceased operating the 3395 residence as rental property from July            
          1989, when they moved from San Jose to Salem and began occupying            
          that residence, until June 1992, when they resumed leasing it.              
               Based on our review of the entire record before us, we find            
          that petitioners have failed to establish that, as of January 31,           
          1992, they were using the 3405 house as their principal resi-               
          dence.  Accordingly, we sustain respondent's determination relat-           
          ing to section 1034.                                                        
               To reflect the foregoing and petitioners' concessions,                 

                                             Decision will be entered for             
                                        respondent.                                   
























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