Bill L. and Nancy L. Turner - Page 5




                                        - 4 -                                         
          flooring, repaired drywall, and painted the interior and exterior           
          of the house.                                                               
               Around October 1994, petitioners decided to sell the Belair            
          property regardless of market conditions.  Petitioners listed the           
          Belair property with Jack White Realty for $275,000.  Within 1              
          week, petitioners received a full-price offer.  On December 5,              
          1994, the sale closed.  The settlement sheet for the sale of the            
          Belair property reflected that the purchasers paid an extra                 
          $499.98 for 1-week’s early occupancy.                                       
               Petitioners never placed a sign in front of the Belair                 
          property nor ran any newspaper advertisements listing it for                
          rent.  Furthermore, the renovation of the Belair property                   
          prevented it from being rented.  By the time petitioners could              
          have rented the Belair property, petitioners had decided “to get            
          rid of” the Belair property.  Petitioners never rented the Belair           
          property, and it remained unoccupied until the new owners moved             
          in on or about November 29, 1994.                                           
               In December 1994, petitioners met with their tax accountant,           
          Fred M. Strand, to discuss their tax liability for 1994.4  Mr.              
          Strand and petitioners discussed the sale of the Belair property,           
          and Mr. Strand’s opinion was that they had converted the property           


               4  For more than 10 years, petitioners met with their tax              
          accountant at the end of the year to help prepare their taxes for           
          that year.                                                                  






Page:  Previous  1  2  3  4  5  6  7  8  9  10  Next

Last modified: May 25, 2011