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petitioners presented no information to corroborate the listing
of the property during 1985 or in any year thereafter.
Petitioners' presence at Mary Street was necessary in part
because of its maintenance requirements. In addition to the
caretakers, petitioners undertook many of the tasks involved in
maintaining the property, such as oiling the citrus groves for
weeds and maintaining the fields. While the citrus groves may
have been a burden on petitioners, they continued to spend time
at the property.
Family Connections: Petitioners’ children, Marc and Julie,
and their grandchildren lived in Riverside in 1988.
Additionally, at least one parent lived in neighboring San
Bernardino during 1988.
Business Location: While Terry's work primarily started in
Riverside in the 1950's, he had an increasing presence in the San
Diego area in the 1970's and 1980's. Petitioners contend that
the location of 20 The Point in the San Diego area was important
to their business and that the Corporation's business needs at
the Alessandro office diminished.
In light of the following, we do not think that Terry's
business leads to the conclusion that petitioners spent the
majority of their time at 20 The Point. While the Corporation
(which was liquidated in August 1988) used 30 The Point and 20
The Point as an office and place for entertaining, it never
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