- 11 - Springs House for resale and moved to Missouri for semiretirement. Once in Missouri, there is no indication that petitioners engaged in any activity designed to enhance the profitability of their alleged "investment". Regarding the rental business of residential property, we have previously held that "Generally, residential property is not purchased for investment purposes where the property is located in a distant city if there are additional costs involved in its management." O'Neill v. Commissioner, supra. We think that given the circumstances, the same principle applies here. We find that the amount of time petitioners spent on the purchase and resale of the Palm Springs House indicates that petitioners did not possess the requisite profit motive. As to petitioners' expertise, we find that although petitioner Mr. Taylor was a real estate agent, he did not use his expertise in this endeavor. First, petitioner Mr. Taylor used his real estate agent's license in the contracting business and not in the sales business. Next, any familiarity that petitioner Mr. Taylor may have had with the residential real estate market was limited to low-price housing and raw land in the Thousand Palms locality. The Palm Springs residential real estate market was different from the Thousand Palms residential real estate market.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011