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property as their principal residence by June 21, 1990. About 15
months after the sale of the Freemont property, petitioners
located and purchased for $314,000 a permanent replacement
residence (Fairway residence). The Fairway residence was an
older residence that petitioners intended to improve and
modernize. The interior of the Fairway residence was functional
and completely inhabitable from the date of petitioners'
purchase. The carport, outside condition, and shrubbery were in
a state of disrepair. At the time of purchase, petitioners did
not move into the Fairway residence. Instead they began some
improvements, including tree removal and limited internal
renovations. They also hired an architect and made plans for
improvements. The planned improvements, however, were changed at
least once prior to the commencement of substantial internal
renovations of the Fairway residence. The architectural plans
that were used for the renovations were dated June 5, 1990.
Petitioners' adult son, Matthew, was transferred to a job
location about 125 miles from his and petitioners' home city.
Matthew sold his home located in the same city as petitioners'
residences, and while he was in transition between jobs and in
the process of establishing his new residence at the new job
location, petitioners allowed Matthew to use the Fairway
residence. Matthew's use of the house was for several months
during the first half of 1990. About the time of Matthew's use,
petitioners installed telephone and cable television service.
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