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Murray helped petitioner repaint the interior of the house
and agreed to repair the bathroom plumbing, repair the patio
awning to the extent possible and remove the irreparable part,
repaint an outside storage shed, replant a flower border, restore
a rock garden, and mend the fence. Murray performed the repair
work; in May 1992, he moved into the house with his girlfriend
and their child.
In December 1992, Murray's girlfriend and child decided to
move to Stockton, California, and Murray informed petitioner that
he intended to follow them. At that time, petitioner decided to
sell her property, rather than offer it for rent to some unknown
persons.
In January 1993, petitioner agreed with a real estate sales
agent to list the property for sale at approximately $230,000;
however, the house did not sell at that price and the
relationship between petitioner and the agent deteriorated. On
March 9, 1993, petitioner relisted the property with Cornish &
Carey, a real estate broker, at a sales price of $219,000. In
listing the property with Cornish & Carey, petitioner signed a
contract authorizing it to be the exclusive broker for her
property. The property was sold in July 1993 for $180,000.
On their 1992 Federal income tax return, petitioners
reported total income of $219,388 without reporting any income or
expenses from the rental activity. On their 1993 return,
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