- 17 - 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 neverPage: Previous 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Next
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