Miguel Martin and Claudia P. Palos - Page 2




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                                  FINDINGS OF FACT                                    
               Petitioners resided at Monrovia, California, at the time               
          their petition was filed.  Petitioners, from 1989 through early             
          1999, owned real property located at 3748 Military Avenue, Los              
          Angeles, California (Military property).  The Military property             
          was first listed for sale on October 1, 1993.  Petitioners had              
          been using the Military property as their personal residence up             
          to the time they began their attempt to sell the property.                  
          Petitioners began moving their furniture out of the Military                
          property shortly after the October 1993 listing for sale.                   
          Petitioners moved in with Mr. Palos’ mother at some time prior to           
          the January 17, 1994, earthquake, and, subsequent to the                    
          earthquake, moved into a newly purchased residence other than the           
          Military property.                                                          
               During 1993, petitioners commenced making improvements and             
          repairs to the Military property in order to enhance its                    
          appearance and value for purposes of sale.  The Northridge                  
          Earthquake occurred on January 17, 1994, and caused damage to               
          petitioners’ Military property.  After the earthquake,                      
          petitioners continued to make improvements to the Military                  
          property and also began to repair the damage caused by the                  
          earthquake.  The improvements, as opposed to repairs from                   
          earthquake damage, appear to represent the significantly greater            
          portion of more than $60,000 in expenditures involving the                  






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