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In April 1990, petitioner accepted employment in Cincinnati,
Ohio, and, at least during the work week, lived in a rented
apartment in the Cincinnati area. Because petitioner’s spouse
was then employed in the Cleveland area, she did not immediately
move to Cincinnati with petitioner. Soon thereafter, however,
she was offered employment in the Cincinnati area. In December
1990 or January 1991, she moved from the Pepper Pike residence,
and petitioner moved from his apartment into a rented house in
the Cincinnati area. On May 15, 1992, they purchased a new
residence in Evendale, Ohio, a suburb of Cincinnati. The parties
stipulated that petitioner and his spouse abandoned the Pepper
Pike residence as their residence when petitioner’s spouse moved
to the Cincinnati area.
The Pepper Pike residence was listed for sale for several
months during 1991, but no offers were received. A real estate
agent suggested that they offer it for rent. In September 1991
the Pepper Pike residence was rented for a 6-month term, which
term was extended for an additional 6 months. The rent charged
and presumably received during the rental period was $1,850 per
month. The Pepper Pike residence remained vacant from October
1992 until it was sold in April 1994. As best as can be
determined from the record, the Pepper Pike residence was sold to
the first person or persons who made an offer to buy it.
For the years during which the Pepper Pike residence was
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