Terry Duane Beall and Joyce Engel Beall - Page 17

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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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