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ordinary and necessary expenses paid or incurred in the
management, conservation, or maintenance of a building
devoted to rental purposes are deductible notwithstanding
that there is actually no income therefrom in the taxable
year, and regardless of the manner in which or the purpose
for which the property in question was acquired. * * *
Furthermore, expenses paid or incurred in connection with
investment property may be deductible under this regulation,
"even though the property is not currently productive and there
is no likelihood that the property will be sold at a profit or
will otherwise be productive of income and even though the
property is held merely to minimize a loss with respect thereto."
Sec. 1.212-1(b), Income Tax Regs. Whether property is held for
the production of income is a question of fact to be determined
from all the facts and circumstances. Johnson v. Commissioner,
59 T.C. 791 (1973), affd. 495 F.2d 1079 (6th Cir. 1974).
On this record, the Court is satisfied that petitioners held
the Florida condominium during 1991 "for the production of
income", within the meaning of section 212(1), and that some of
the expenses incurred with respect thereto during 1991 were for
"the management, conservation, or maintenance" of the Florida
condominium, as provided in section 212(2). Petitioner and Mrs.
Thomason purchased the Florida condominium for the purpose of
making a profit on resale. They intended to lease the Florida
condominium to derive income during the period in which they were
unable to sell the property, and they incurred expenses to
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