- 3 - 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 morePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011