Gary B. and Kathleen Mitchell - Page 3

                                        - 3 -                                         
          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.               




Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  Next

Last modified: May 25, 2011