Richard A. Pettit - Page 4

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          attract more customers for his business.  He enlisted a real                
          estate agent in April 1989 to promote its sale.                             
               The construction project proceeded smoothly.  As the general           
          contractor, petitioner constructed the majority of the two-story            
          house himself, including framing, roofing, siding, and installing           
          the windows, cabinets, and doors.  He obtained assistance from              
          his father and other individuals for certain work such as                   
          erecting the frame of the house, insulating the house, and                  
          constructing the fireplace, chimney, and staircases.  In                    
          addition, the plumbing and electrical wiring were required by law           
          to be performed by licensed subcontractors.                                 
               In February 1990, petitioner and his wife separated.  The              
          problems that resulted had a serious negative impact on his                 
          construction business.  For a period of time immediately                    
          following the separation, petitioner's wife took possession of              
          his truck with all of his tools.  Shortly thereafter, she placed            
          a lien on the East Lyme property to protect her interests in the            
          event it was sold by petitioner.  The additional legal issues               
          connected with the lien discouraged potential buyers.  In                   
          addition, the real estate market took a significant downturn in             
          the early 1990's.  Under these circumstances, petitioner was                
          unable to secure a buyer for the East Lyme property.                        
               Petitioner could not make the construction loan payments as            
          a result of financial difficulties caused by his separation.  He            
          deeded the East Lyme property to Mechanics Savings Bank in lieu             




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