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for 15 Sandpiper was $950,000, and the home was purchased fully
furnished for an additional $250,000.
On November 29, 1988, petitioners changed their voter
registrations from Riverside County to San Diego County, listing
15 Sandpiper Strand as their new address. Upon the expiration of
his driver's license on January 26, 1989, Terry changed the
address of his residence to reflect 15 Sandpiper.
On March 1, 1989, petitioners hired a moving company to move
their furnishings from 20 The Point to 15 Sandpiper.
In 1989, petitioners received a homeowners' exemption for 15
Sandpiper.
3 Green Turtle
Petitioners purchased a vacant lot located at 3 Green Turtle
Road, Coronado, California (3 Green Turtle) on December 1, 1988.
3 Green Turtle is a residential lot located in Coronado Cays,
within the same neighborhood as 20 The Point and 15 Sandpiper.
Terry believed the lot to be "superior" because it was located on
a main channel, with a "bigger dock space," and an "unobstructed
view of Coronado Bridge."
1989 Federal Income Tax Return
On their 1989 Federal income tax return, petitioners
reported the sale of 20 The Point. They executed a Form 2119,
Sale of Your Home, with respect to 20 The Point. They attached
this form to their return, thereby claiming the right to defer
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