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The Burns Street property was petitioner’s personal
residence from March 1989 to December 10, 1993. On December 10,
1993, petitioner sold the Burns Street property for an adjusted
sales price of $127,920. Petitioner realized $9,123 of gain on
the sale of the Burns Street property.
From January 1994 through September 1995, petitioner lived
on his boat docked at a marina in Portland, Oregon. In late
September 1995, petitioner and a friend sailed petitioner’s boat
to Astoria, Oregon, and docked it there.
In August 1995, Uprite Homes, Inc. (Uprite Homes),
petitioner’s wholly owned S corporation, completed construction
of a residential property located in Washington County in
Sherwood, Oregon (the Bowmen Lane property). Petitioner began to
sleep at the Bowmen Lane property in October of 1995. The Bowmen
Lane property was unfurnished, and petitioner did not keep his
personal belongings in the house. He slept at the Bowmen Lane
property in a sleeping bag that he stored in his camper during
the day. He also showered at the Bowmen Lane property but stored
his toiletries in his camper afterwards. He did not cook meals
at the house although he did eat in the house some meals
purchased from fast food restaurants. Petitioner did not receive
mail at the Bowmen Lane property.
Between October 1 and December 6, 1995, the utilities and
insurance for the Bowmen Lane property were in the name of Uprite
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