Neal T. Baker Enterprises, Inc. - Page 30

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          that the house located at 1030 Pennsylvania Avenue took                     
          approximately 19 months to sell.                                            
               However, petitioner's arguments oversimplify the facts.  In            
          determining the holding period, we need to know when the houses             
          were completed and compare this to the sales dates.  Examining              
          the record, we find the final inspection date of each of the 14             
          houses.  Mr. Baker stated that each house was completed (except             
          for the appliances, fixture, carpets) and ready for sale prior to           
          the final inspection date.  Due to problems in the area                     
          (vandalism, etc.), in some instances the final inspection did not           
          occur until shortly before the house was sold.  But petitioner              
          presented no evidence to show when the houses were substantially            
          completed.                                                                  
               The final inspection date and the sale date for each house             
          are as follows:                                                             
          Final Inspection Date Date of Sale      Address             Phase           
               07/10/87       07/21/87       1202 E. 10th Street      1               
               07/23/87       09/30/87       1050 Pennsylvania Avenue 1               
               07/23/87       12/22/87       1070 Pennsylvania Avenue 1               
               07/23/87       01/08/88       1090 Pennsylvania Avenue 1               
               07/23/87       09/16/88       1010 Pennsylvania Avenue 1               
               08/23/88       09/23/88       1110 Pennsylvania Avenue 2               
               08/23/88       11/17/88       1202 E. 11th Street      2               
               10/31/88       11/22/88       1201 E. 11th Street      2               
               01/23/89       01/27/89       1130 Pennsylvania Avenue 2               
               02/06/89       02/10/89       1120 Pennsylvania Avenue 2               
               07/23/87       02/28/89       1030 Pennsylvania Avenue 1               
               10/21/88  03/06/89            1100 Pennsylvania Avenue 2               
               02/23/89       03/13/89       1140 Pennsylvania Avenue 2               
               02/27/89       03/31/89       1150 Pennsylvania Avenue 2               








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