Ronald P. Barranti and Stephanya M. Barranti - Page 4

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          comparable properties for rent, and determined that the fair                
          market rental amount was between $700 and $750 per month.                   
               To prepare the property for habitation, petitioner first               
          cleared the house of the decedent's personal property and then              
          began making repairs.  Although petitioner was not an experienced           
          home repair person, she wanted to do as much of the repair work             
          herself as possible to minimize its expense.  Accordingly,                  
          petitioner called various contractors to come to the property to            
          explain what needed to be done and to submit a bid for the work.            
          After receiving the advice, petitioner thanked the contractors              
          for their time, purchased the required materials, and did the               
          work herself.  For instance, petitioner scraped the mildew from             
          the interior walls, recaulked the windows and sealed the ground             
          under the house to prevent moisture from entering and reviving              
          the fungus, and sanded and refinished the hardwood floors.                  
               Because petitioner worked on the property only during                  
          weekends, the repairs took several months.  During this time,               
          petitioner's awareness of the character of the neighborhood and             
          the risks of renting to someone who might prove to be an                    
          irresponsible tenant increased.  In December 1991, petitioner               
          began negotiating with her brother, Ronny Murray (Murray), to               
          rent the house to him in exchange for $500 per month plus                   
          utilities, and his agreement to help petitioner finish the repair           
          work and maintain the property.                                             





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