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he would like to build a house on the lot for his own residence",
and for that reason it was suggested that title be changed from
Terry's Retirement Trust to his living trust. This letter
provides us with McKenzie's view of petitioners' intentions and
with an explanation for the change in title. We note that
petitioners purchased 3 Green Turtle, which was a vacant lot, 3
months after acquiring 20 The Point, and after the acquisition of
15 Sandpiper.
Considering the facts and circumstances, during the relevant
period, we find that petitioners had the intent of remaining at
20 The Point from August 31, 1988, the date of acquisition, until
November 21, 1988, when their purchase of 15 Sandpiper was
completed.
Fact of Abode
Generally, for property to be "used by the taxpayer as his
principal residence" within the meaning of section 1034(a), a
taxpayer must physically occupy and live in the dwelling.
Houlette v. Commissioner, 48 T.C. 350, 354 (1967); Stolk v.
Commissioner, supra at 353-356. It has long been recognized that
moving furniture into a house or spending weekends in a house
does not make that house a taxpayer's principal residence. King
v. Commissioner, 72 T.C. 349, 355 (1979). A taxpayer must live
in a house on a regular day-to-day basis in order for the house
to be his "principal residence" within the meaning of section
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