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short time (well within the 2-year requirement of section 1034).
Thus, petitioner did not have more than one “principal
residence”. Sec. 1.1034-1(c)(3), Income Tax Regs.
Considering the above principles and the record in this
case, the Walnut Creek property was petitioner’s principal
residence. Respondent does not contend that any other
requirement of section 1034 was not satisfied. Accordingly,
petitioner was entitled to defer any gain realized on the 1987
sale of that property.
VI. Deduction of Losses From Horse Breeding Activity
Petitioner claimed losses for 1987 through 1991 of $88,047,
$40,811, $65,647, $116,737, and $27,351, respectively, from the
operation of the JAC Ranch. The losses were claimed on what
purported to be joint returns filed by petitioner and Mrs.
Corrigan. Because the horse breeding activity to which these
claimed losses are attributable was operated by and in the name
of Mrs. Corrigan, and because petitioner was not entitled to file
a joint return, he now contends that he and Mrs. Corrigan
operated the activity as a joint venture, and that he is entitled
to claim all of the losses reflected on the purported joint
returns for 1987 through 1991.
Respondent disallowed the losses in their entirety, and the
parties’ dispute concerns the question of whether petitioner was
entitled, as a joint venturer, to all of the losses for the horse
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