Don and Margaret Taylor - Page 14

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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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