-5-
Petitioners' Residence
Beginning June 1, 1981, petitioners resided at 2311 Apricot,
Irvine, California (Apricot), a condominium with two bedrooms and
a loft.
On January 23, 1988, petitioners executed a "Reservation
Instrument" and made a deposit to purchase a residence located at
14 Siros, Laguna Niguel, California (14 Siros). They entered
into a purchase and sale agreement for 14 Siros on March 15,
1988, agreeing to acquire that residence for $274,900. In March
1988, they executed various documents selecting custom options
for paint, tile, and other features of the residence to be
completed at 14 Siros.
During 1988, homes in an exclusive gated community in Laguna
Niguel were made available to prospective purchasers through a
lottery conducted by Standard Pacific, L.P. (Standard Pacific).
Petitioners participated in the lottery and were selected to
acquire a residence at 25 Hastings, Laguna Niguel, on April 30,
1988. On May 1, 1988, petitioners executed a reservation
document and made a deposit for purchase of 25 Hastings.
On or after May 11, 1988, petitioners executed escrow
instructions that referred to the purchase of 14 Siros as
relating to "a 1031 tax deferred exchange". The exchange
provision of the escrow instructions was canceled in June 1988.
Construction at 14 Siros and petitioners' purchase of that
property were completed on August 2, 1988.
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