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for petitioner’s children, Mr. Matre and his family, and other
regular guests.
Renovation of the lodge began in the spring of 1988 and was
substantially completed by the end of that year. The lodge,
however, was not habitable until March 1989 when furniture was
first moved into the lodge. During the renovation period,
petitioner and his family visited on a weekly or biweekly basis
so that petitioner could supervise the contractors and his family
could enjoy the property. Until the lodge was habitable,
petitioner’s family and Mr. Matre’s family stayed in the
farmhouse.
The cost of capital improvements to Granot Loma from October
1, 1987, through December 31, 1992, totaled $2,504,794.
Petitioners’ Use of Granot Loma
Before acquiring Granot Loma, petitioners took vacations to
various locations around the world, including long trips on
holidays. From the date they acquired Granot Loma through August
1990, petitioners spent almost every holiday at Granot Loma.
During the years at issue, petitioners and their family
personally used Granot Loma as follows:
Year Days Used
1988 68
1989 79
1990 71
1991 66
1992 51
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Last modified: May 25, 2011