Don and Margaret Taylor - Page 5

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          Property at a price of $132,500.  Petitioners used the cash                 
          obtained from the Thousand Palms Property sale/exchange for the             
          Missouri Property purchase.  Upon obtaining the Missouri                    
          Property, petitioners promptly moved to Missouri.                           
               At about the same time; i.e., immediately after obtaining              
          the Palm Springs House, petitioners listed the house for sale               
          with a real estate agent.  The list price for the Palm Springs              
          House was $525,000, but the listing stated that as petitioners              
          were absentee owners they would accept most offers.  In the                 
          interim, petitioners did not offer the Palm Springs House for               
          rent.  The Palm Springs House had never been lived in, and                  
          renting it might have caused a reduction in the value of the                
          house.  In the meanwhile, petitioners incurred mortgage interest            
          expense on the Palm Springs House mortgage.  Petitioners paid the           
          mortgage interest expense through an escrow account set up by               
          petitioners at the time of their purchase.  Petitioners                     
          established the escrow account for their convenience because they           
          intended to sell the Palm Springs House immediately.                        
               Petitioner Mr. Taylor was a real estate agent.  However, he            
          used his real estate agent's license in the contracting business            
          and not in the sales business.  He was not the listing agent for            
          the sale of the Thousand Palms Property or subsequently for the             
          Palm Springs House.  However, petitioners had in the past: (1)              
          Purchased low cost residential properties in Thousand Palms,                





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Last modified: May 25, 2011