- 8 - Because we find that petitioners held neither property for investment, we make no findings of fact relating to the sufficiency of petitioners’ attempt to satisfy the other requirements for a deferred like-kind exchange.5 Petitioners’ Purchase and Use of the Properties The Clark Hill Property Petitioners’ decision to purchase the Clark Hill property was motivated, in part, by their familiarity with the area, both having grown up in the vicinity of Clark Hill Lake. In addition, both their families owned property on or near Clark Hill, and Mr. Moore’s father advised them that property on Clark Hill Lake had appreciated and would continue to appreciate. Petitioners’ decision to invest in real estate rather than in intangibles, such as stocks or bonds, was influenced by a prior bad experience with a financial adviser who had stolen their money. When in 1988 they purchased the Clark Hill property, petitioners’ primary residence was in Norcross, Georgia, an approximately 3-hour drive from the Clark Hill property. In 1995 or 1996, petitioners changed their primary residence to Marietta, Georgia. The drive from the Marietta residence to the Clark Hill property normally took between 5 and 6 hours. 5 As a result, we need not rule on respondent’s objections to various documents petitioners offered.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: November 10, 2007