Don and Margaret Taylor - Page 3

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          5 acre parcel of land.  For tax purposes, petitioners treated 25            
          percent of this property as used for business.                              
               Petitioners planned to move to Missouri for semiretirement.            
          In this regard, petitioners entered into a contract to purchase a           
          campground in Missouri (the Missouri Property) in October 1990.             
          Petitioners paid an $11,000 earnest money deposit toward this               
          contract.  Petitioners intended to use a portion of the Missouri            
          Property as a residence and to rent the other portions to                   
          supplement their retirement income.                                         
               Thereafter, in November 1990, petitioners listed the                   
          Thousand Palms Property for sale at a listing price of $650,000.            
          Given its uniqueness, petitioners hoped that an individual in the           
          construction business would be interested in their property.                
          Sometime in January 1991, petitioners were contacted by a married           
          couple, Mr. and Mrs. Norris (the Norrises).  The Norrises                   
          proposed a transaction to exchange properties with petitioners.             
          The Norrises owned a single-family home on a 1-acre lot in Palm             
          Springs, California (the Palm Springs House).  The Palm Springs             
          House was listed at $529,000 and had been on the market for more            
          than 4 months.                                                              
               Even though Palm Springs and Thousand Palms are neighboring            
          communities, their residential real estate markets are not                  
          similar.  Palm Springs homes are typically larger and much more             







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