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Moore spent considerable time fixing up and maintaining both
properties and petitioners made substantial improvements at the
Clark Hill property, those actions are consistent with enjoying
the properties as vacation homes. Petitioners did not hold the
Clark Hill property out for rent or sale, yet they added a deck
and screened-in porch, installed a satellite television receiver,
and purchased a television, a VHS recorder, and a new washer and
dryer for their use at the property. They replaced furniture and
kept a boat on the lake, which they used for boating and fishing.
Petitioners added similar electronic equipment to the Lake Lanier
house. That house was of some substance, containing five
bedrooms and having, among other amenities, five screened-in
porches overlooking the lake, a double slip dock, a great room
with a stone fireplace, and a full party deck. Surely, that
house represented a substantial portion of the purchase price of
the Lake Lanier property, yet petitioners made no effort to
recover any portion of that investment by renting the house out;
indeed, they did not even offer it for rent. Petitioners would
have us believe that they used the house only as a caretaker’s
cottage while awaiting the expected appreciation in the value of
the property as a whole. While awaiting that event, however,
they purchased a 6- to 8-passenger motorboat to pass the time on
the lake. Also inconsistent with their claim that they held the
two properties for investment is their failure to claim any tax
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