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20 The Point was a 3,200-square-foot home, with four
bedrooms and two master bedroom suites, on the Coronado Cays
waterfront with a 40-foot dock. As with 30 The Point, 20 The
Point was used by the Corporation as a business asset. The
Corporation took depreciation deductions on the property for the
period April 27, 1983, to July 31, 1988. 20 The Point was used
as an office for the Corporation. Additionally, it was used as
an alternative to hotel rooms for the Corporation's employees and
agents, and as a place to entertain clients. From its own dock,
the Corporation took clients out on the bay.
When the Corporation was liquidated in August of 1988,
petitioners received 20 The Point. The deed conveying 20 The
Point to them was dated August 31, 1988, and recorded on
September 23, 1988.
Petitioners continued to have an office at 20 The Point
after the liquidation.
On September 28, 1988, petitioners listed 20 The Point for
sale. On December 30, 1988, petitioners entered into a Real
Estate Purchase Contract and Receipt for Deposit for the sale of
20 The Point. On March 9, 1989, the sale of 20 The Point was
closed.
For the years 1988 and 1989, petitioners did not apply for a
homeowners' exemption on 20 The Point. Petitioners never
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Last modified: May 25, 2011