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Many factors support respondent's theory. The Thousand
Palms Property was a highly specialized property. The property
included a single-family home, a construction work area, and a
mobile home. Petitioners realized that only a limited group of
individuals would be interested in such a property. As
previously noted, it was the Norrises who contacted petitioners.
The Norrises were willing to purchase the Thousand Palms Property
if petitioners would purchase their home; i.e., the Palm Springs
House. As a new single-family house, the Palm Spring House was
probably easier to sell. Furthermore, the sale/exchange
transaction was designed in such a manner to provide petitioners
with the additional cash required to purchase the Missouri
Property. In fact, petitioners used the cash thus obtained to
close their purchase of the Missouri Property. Also, petitioners
immediately listed the Palm Springs House for resale in order to
complete the transaction and their move to Missouri. Thus, we
view petitioners' sale/exchange of one property for another and
the immediate resale of the latter, as primarily motivated by
personal reasons.
Hence, despite the fact that petitioners did not purchase
the Palm Springs House for use as their personal residence, we
think that petitioners' motive was more personal in nature. See
O'Neill v. Commissioner, T.C. Memo. 1985-92; Nicath Realty Co.,
Inc. v. Commissioner, T.C. Memo. 1966-246. Here, although we
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