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(2) During 1987, petitioner entered into a predevelopment
purchase agreement for office space described as Suite 11, 1410
Energy Park Drive, that required her to pay $85,000 for the
office once the development work was completed. For
approximately 4 months before petitioner actually moved into
Suite 11, she rented Suite 8 and used it as her temporary law
office. Petitioner paid $955 per month to the Trah Partnership
for 4 months (Ex. 38-R, lines 164-165, 1066-1067), and respondent
has conceded that these amounts are deductible.
(3) In July 1987, petitioner moved into Suite 11 but did not
close on the purchase agreement because she could not get the
developer to schedule the closing. Petitioner maintained her law
office in Suite 11 until 1990 when the developer’s interest in
the property, 1410 Energy Park Drive, was foreclosed.
(4) When petitioner first moved into Suite 11 in July 1987,
she agreed to pay rent at the rate of $1,239.47 per month until
the closing under the purchase agreement was held. Petitioner
expected this arrangement to be of short duration. No closing,
however, was ever scheduled. Sometime after she moved into Suite
11, petitioner ceased paying rent to the developer in an effort
to force a closing under the purchase agreement. Petitioner was
sued for unpaid rent and resolved the litigation by escrowing
approximately $10,000 in 1990 to settle the claim. However, the
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