Don and Margaret Taylor - Page 13

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          of real estate through a third-party real estate agent.  In                 
          addition, petitioners surely realized that they would incur                 
          mortgage interest expense prior to the resale of the Palm Springs           
          House.  Any possible profit would have been eroded, if not                  
          eliminated, by such expense.  Under these circumstances, we find            
          that petitioners did not obtain the Palm Springs House with the             
          expectation that they could benefit from a possible appreciation            
          in its value.                                                               
               Our examination of the relevant profit motive factors                  
          delineated under section 1.183-2(b), Income Tax Regs., leads us             
          to conclude that although petitioners "hoped" for some profit,              
          they did not have the requisite profit motive to claim a loss               
          under section 165(c)(2).                                                    
               Rather, we agree with respondent that petitioners' primary             
          motive in purchasing the Palm Springs House was to get one step             
          closer to moving to Missouri.  We are persuaded by respondent's             
          argument that petitioners were eager to move to Missouri for                
          semiretirement, that they anticipated some difficulty in selling            
          the Thousand Palms Property, and that the sale/exchange with the            
          Norrises for a single-family home enabled them to: (1) Move to              
          Missouri, and be left with the less onerous task of selling a               
          single-family home in a more populated area; and (2) obtain the             
          additional cash required for their purchase of the Missouri                 
          Property.                                                                   





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