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necessitated by petitioners’ plans for the new structure to
include, on two floors, a living room, kitchen, great room,
bedrooms, bathrooms, laundry room, art studio, and garage, such
that two fully functional dwelling structures would be located on
the single lot.
After the building permit was approved in March of 1993,
petitioner was able to begin construction. In order to reduce
cost, he did most of the work himself, when his employment in and
income from the film production industry would allow.
From April 21, 1992, to December 22, 1993, petitioners made
capital expenditures of $210,545.96 relating to the Turlock
property, in connection with either the existing residence or the
new structure. When these costs are combined with the purchase
price, the amount spent totals $380,045.96. Nonetheless, as of
December 24, 1993, petitioners had never slept in the new
structure. There was no central heating to the house at that
time. The rough electrical, plumbing, and heating/ventilation
systems were not approved until September of 1997. The kitchen
and garage were being used as a workshop at the end of 1993.
Only one bath had a sink and toilet installed. As of early 1999,
construction work continued in the living room, kitchen, great
room, bedrooms, bathrooms, laundry room, and art studio of the
new structure. Petitioners’ furniture and household goods
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