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Whether a former residence used for personal purposes has
been converted in the hands of the same taxpayer to property held
for the production of income is a question of fact to be resolved
with reference to the surrounding facts and circumstances.
Newcombe v. Commissioner, 54 T.C. 1298 (1970). Five factors have
been identified by this Court and other Federal Courts in
deciding previous cases involving similar questions; those
factors include: (1) The length of time the house was occupied by
the individual as his residence before placing it on the market
for sale; (2) whether the individual permanently abandoned all
further use of the house; (3) the character of the property
(recreational or otherwise); (4) offers to rent; and (5) offers
to sell. Grant v. Commissioner, 84 T.C. 809, 825 (1985), affd.
without published opinion 800 F.2d 260 (4th Cir. 1986); see also
Bolaris v. Commissioner, 776 F.2d 1428, 1433 (9th Cir. 1985),
affg. in part and revg. in part on another ground 81 T.C. 840
(1983); Newcombe v. Commissioner, supra at 1300-1301. No one
factor is determinative; rather, all the facts and circumstances
must be considered. Grant v. Commissioner, supra at 825;
Newcombe v. Commissioner, supra at 1300-1301.
Petitioner and his spouse purchased the Pepper Pike
residence in 1978 to be used as their family residence. They did
not originally acquire it for investment or income producing
purposes. Following its purchase, petitioner and his spouse
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