John T. Talkington and Margaret K. Talkington - Page 4

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               In July of 1986, Mr. Talkington and Mr. Sessions purchased             
          the Litton property from Litton for $600,000.  Mr. Talkington and           
          Mr. Sessions each owned a 50-percent undivided interest in the              
          Litton property.                                                            
               During the 6 years that Mr. Talkington and Mr. Sessions                
          owned the Litton property, it was never occupied or leased.  Also           
          during this time, the Litton building suffered from normal wear             
          and tear, deferred maintenance, and vandalism.  The deferred                
          maintenance on the Litton building included the following:  (1)             
          The parking lot asphalt was cracked, and the face was coming off            
          in places (the cracks needed sealing and the lot possibly needed            
          to be resurfaced); (2) the concrete flatwork on the sidewalks,              
          drives, and walks was cracked, and the face was coming off; (3)             
          there was a broken window in the north entrance; (4) the                    
          landscaping had been neglected, and some shrubs and trees were              
          dead; (5) the floor tiles were damaged due to flooding in the               
          past; (6) many ceiling tiles were missing, stained, and/or in               
          poor repair; and (7) the walls were dirty and/or stained from               
          draining of the building's sprinkler system.  Additionally, the             
          copper hot and chilled water piping had been stolen from the                
          Litton building.                                                            
               The Lubbock Central Appraisal District (LCAD) determined the           
          appraised value of the Litton property to be $570,912 as of July            
          14, 1989.  Petitioners appealed this assessed value and hired               





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