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Clark Hill property. They visited the property two weekends per
month beginning in mid-March (depending on the weather) and
ending around Labor Day. In addition, the family might visit the
property once or twice each winter, and Mr. Moore and his son
would fish off the dock one Saturday night each month during the
fall. During the summer months, petitioners occasionally
entertained visitors at the house. Mr. Moore’s maintenance
activities at the Lake Lanier property were similar to, but less
frequent than, his maintenance activities at the Clark Hill
property.
The mortgage lender in connection with petitioners’ purchase
of the Lake Lanier property was SouthTrust Bank, N.A. (SouthTrust
Bank).6 On their 2000-02 Federal income tax returns, petitioners
claimed deductions for home mortgage and investment interest paid
to SouthTrust Bank as follows:
Year Home Mortgage Interest Investment Interest
2000 $36,219 $5,647
2001 42,437 1,994
2002 45,766 --
As in the case of the Clark Hill property, petitioners did
not list on their 2000-02 returns any deductions for maintenance
or other expenses associated with the Lake Lanier property.
6 In its “Credit Offering Report” assessing the risk of
various loans to Ms. Moore, including the loan to purchase the
Lake Lanier property, that property, which was to serve as
security for those loans, is consistently referred to as a
“second residence”.
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Last modified: November 10, 2007