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FINDINGS OF FACT
A. Petitioners
Petitioners are married and lived in Clinton, Sampson
County, North Carolina, when they filed their petition.
Petitioners have a daughter who attended high school in 1990 and
1991.
Petitioner has lived in Sampson County all of his life. He
has farmed since he was 13 years old. He is a college graduate
with a degree in history. He has been a licensed realtor since
1974, when he started to work in the real estate business. In
1987, he became a director of a bank. He sometimes borrowed
money from his great-aunt, Mary McCullen.
In 1990 and 1991, Mrs. McCullen was employed as a teacher
with the Clinton City Schools. She earned $29,506 in 1990 and
$31,220 in 1991.
B. Petitioner's Real Estate Activities
1. Petitioner's Purchase of Real Estate
Petitioner bought various parcels of real estate before and
during 1990 and 1991. In 1990 and 1991, petitioner owned the
Bass Town tract, Sadie Farm, Greenview tract, and Giddonsville
Packing tract. He intended to resell the properties but did not
do so during the years in issue for various reasons. He borrowed
money from various financial institutions to buy the properties.
Petitioners deducted interest related to these real estate
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