Barry E. Moore and Deborah E. Moore - Page 10




                                       - 10 -                                         
               Until they decided to acquire the Lake Lanier property in              
          late 1999, petitioners had never advertised the Clark Hill                  
          property for sale although they had been offered money for it.              
          Also, petitioners never rented or attempted to rent the property            
          to others.                                                                  
               On their 1996-99 Federal income tax returns, petitioners               
          listed deductions for “home mortgage interest”.  They did not               
          list on those returns any deduction for investment interest, nor            
          did they deduct any maintenance or other expenses associated with           
          the Clark Hill property.                                                    
                    The Lake Lanier Property                                          
                    Reasons for Purchase                                              
               After petitioners changed their principal residence from               
          Norcross to Marietta, Georgia, the length of the drive to the               
          Clark Hill property coupled with their children’s increased                 
          weekend activities (in particular, their son’s participation in             
          weekend sports) made it inconvenient for the family to spend                
          weekends at the property.  As a result, they used that property             
          less frequently and, during the 2 years before their disposition            
          of it, they may have visited the property a total of three times.           
          During that period, it became a chore for Mr. Moore just to                 
          maintain the property, with the result that it became rundown and           
          had to be either renovated or disposed of.                                  








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