Don and Margaret Taylor - Page 12

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               Furthermore, petitioner Mr. Taylor was not the listing agent           
          on the sale of the Palm Springs House.  Rather, petitioners moved           
          to Missouri immediately after the purchase of the house and                 
          listed their house with another real estate agent.  Thus, even if           
          petitioner Mr. Taylor possessed any expertise in the residential            
          real estate activities, he did not utilize the same in the resale           
          of the Palm Springs House.                                                  
               We also believe that petitioners did not obtain the Palm               
          Springs House with the expectation that it might appreciate in              
          value.  Petitioners contend that they expected to make a quick              
          profit from the sale of the Palm Springs House.  Petitioners                
          purchased the Palm Springs House at a reduced price of $460,000             
          after the house had been on the market for 4 months.  This price            
          was $69,000 less than the price at which it was listed.                     
          Petitioners maintain that they were not aware of any decline in             
          the real estate market at the time of their purchase of the Palm            
          Springs House, yet they were not alarmed that the Norrises had              
          been unable to sell the house during the 4-month listing period             
          or that they were willing to accept such a reduced price.                   
               Petitioners claim that they hoped to make a "quick" $60,000;           
          i.e, a 13 percent, profit.  We think that petitioners could not             
          realistically have had such expectations.  There is no reason to            
          surmise that petitioners were unaware of the costs, sometimes               
          exceeding 10 percent of the sales price, associated with the sale           





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