J. Clark and Mary R. Bundren - Page 4




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          residential listings because the real estate market was very                
          slow.                                                                       
               As a result, in the spring of 1994, after conferring with              
          their accountant, Mr. Patrick Walters (Walters), petitioners                
          decided to convert the 84th Street property to rental property.             
          From September to December 1994, petitioners rented the 84th                
          Street property for a few hundred dollars a month.                          
          Exchange of the 84th Street Property                                        
               Because of liability concerns associated with renting the              
          84th Street property, petitioners decided to dispose of it.                 
          Petitioners listed the 84th Street property for sale at $134,500.           
          Petitioners’ goal, however, was to find a person willing to                 
          exchange rental properties so that petitioners could obtain                 
          property in a part of town they believed more suitable for rental           
          purposes.  Petitioners informed their real estate agent of their            
          desire to exchange rental properties.                                       
               Through the efforts of their real estate agent, petitioners            
          were introduced to Ms. Delores Henson Youngblood (Youngblood),              
          who owned the 116th East Ave. property.  In September 1994,                 
          Youngblood had listed the 116th East Ave. property for sale for             
          $67,500 with the realtor petitioners were using.  Youngblood was            
          interested in moving out of the part of town where the 116th East           
          Ave. property was located and into the part of town where the               








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