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Petitioners’ Purchase of the 84th Street Property
On July 30, 1982, petitioners purchased a house at 4714 East
84th Street in Tulsa, Oklahoma (the 84th Street property), for
approximately $183,000. Petitioners used the 84th Street
property as their primary residence until they converted it to
rental property in the spring of 1994. Altogether, petitioners
spent approximately $50,130 on improvements to the 84th Street
property, thereby increasing their total investment in the
property to approximately $233,130. All these improvements were
made while petitioners used the 84th Street property as their
primary residence.
In October 1992, the Green Country Appraisal Service
appraised the 84th Street property as having a fair market value
of $150,500.
Conversion of the 84th Street Property to Rental Property
In 1994, petitioners moved to a house located at 3120 East
87th Street in Tulsa, Oklahoma (the 87th Street property).
Although petitioners preferred to sell the 84th Street
property, a rise in conventional mortgage rates during the summer
of 1994, coupled with the large number of houses on the market,
made the sale of residential property in Tulsa difficult. The
Tulsa real estate market had been in decline since 1982. In
1994, the Multiple Listing Service in Tulsa (a service which
listed real estate for sale) had essentially stopped taking
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