Tommy Owens, Jr. and Dawn R. Owens - Page 9




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          Street property).5  With respect to the Massachusetts Street                
          property, petitioners also made during 1995 at least (1) one                
          mortgage payment of $1,000, (2) a payment of $292.56 with respect           
          to telephone service, and (3) payments totaling $220.79 for                 
          materials.                                                                  
               Ms. Owens visited her mother in Lebanon, Missouri (Lebanon),           
          at least twice each year.  Ms. Owens’ visits to her mother                  
          usually lasted between one week and one month.  During 1994, Ms.            
          Owens was snowed in during one of those visits.  As a result, Ms.           
          Owens stayed in Lebanon for two months.  When Ms. Owens traveled            
          to visit her mother in Lebanon, she took money with her for her             
          expenses.  During 1994, when Ms. Owens stayed for two months                
          because of a snowstorm, Mr. Owens wired her some money.                     
               Mr. Owens filed Form 1040, U.S. Individual Income Tax                  
          Return, for taxable year 1990, which showed a loss for that year            
          of $13,779.  Mr. Owens and Ms. Owens jointly filed a return                 
          (joint return) for each of the taxable years 1991 and 1992.                 
          Those joint returns showed losses for 1991 and 1992 of $5,817 and           
          $31,843, respectively.  The loss that Mr. Owens reported in his             
          1990 return was equal to the loss that he claimed in Schedule C             
          of that return, reduced by $121 of taxable interest that he                 
          reported in that return.  The loss that petitioners reported in             


               5The record does not disclose the location of the Massachu-            
          setts Street property.                                                      





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