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In 1989 and 1990, petitioner generally paid the installments

on the New Jersey house mortgage, as well as the taxes and

related fees associated with the undeveloped land in Florida, the

Brookdale timeshare, and the Gulfstream timeshare, from the LTG

account.

Petitioner advertised the New Jersey house for sale and

found

a

buyer.

However,

the

buyer

under

the

contract

of

sale

defaulted,

and

the

sale

did

not

go

through.

(Petitioner

was

relying on the proceeds from the sale of the New Jersey house to

repay

loans

for

constructing

the

Florida

house.)

After

the

buyer

defaulted, petitioner obtained money from his brother ($105,000)

and Mrs. Wood’s mother ($100,000) to assist with the cost of

constructing

the

Florida

house.

Petitioner

paid

an

additional

$155,000 of the cost and obtained a loan for the balance.

Petitioner and Mrs. Wood moved into the Florida house in

August 1990 and listed the New Jersey house for sale with a real

estate

agent.

The

real

estate

agent

rented

the

New

Jersey

house

for petitioner on a month-to-month basis from 1992 until it sold

in

1994.

A

lease,

dated

March

15,

1993,

specified

that

the

New

Jersey house would remain on the market for sale and could be

shown

to

prospective

buyers

by

appointment.

The

lease

also

provided that, if a contract of sale was accepted, the tenant

would be given 90 days’ notice to vacate the property.

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