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In 1989 and 1990, petitioner generally paid the installments
on the New Jersey house mortgage, as well as the taxes and
related fees associated with the undeveloped land in Florida, the
Brookdale timeshare, and the Gulfstream timeshare, from the LTG
account.
Petitioner advertised the New Jersey house for sale and
found a buyer. However, the buyer under the contract of sale
defaulted, and the sale did not go through. (Petitioner was
relying on the proceeds from the sale of the New Jersey house to
repay loans for constructing the Florida house.) After the buyer
defaulted, petitioner obtained money from his brother ($105,000)
and Mrs. Wood’s mother ($100,000) to assist with the cost of
constructing the Florida house. Petitioner paid an additional
$155,000 of the cost and obtained a loan for the balance.
Petitioner and Mrs. Wood moved into the Florida house in
August 1990 and listed the New Jersey house for sale with a real
estate agent. The real estate agent rented the New Jersey house
for petitioner on a month-to-month basis from 1992 until it sold
in 1994. A lease, dated March 15, 1993, specified that the New
Jersey house would remain on the market for sale and could be
shown to prospective buyers by appointment. The lease also
provided that, if a contract of sale was accepted, the tenant
would be given 90 days’ notice to vacate the property.
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