Stewart and Shirley Oatman - Page 3

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               4.   Whether petitioners may deduct $1,304.14 they claim               
          they paid to refinance their W. 66th Street rental property.  We            
          hold that they may not.                                                     
               5.   Whether petitioners may deduct as a bad debt the amount           
          of a late rent penalty ($2,219) to which petitioners contend they           
          were entitled but did not receive.  We hold that they may not.              
               6.   Whether petitioners are liable for the accuracy-related           
          penalty for negligence for 1999.  We hold that they are.                    
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          A.   Petitioners                                                            
               Petitioners are married and lived in Los Angeles,                      
          California, when they filed their petition in this case.                    
          B.   Petitioners’ Rental Properties                                         
               Petitioners bought a four-unit residential rental property             
          at 8200, 8202, 8204, 8206 Crenshaw Blvd. (Crenshaw Blvd.                    
          property) for $222,305.91 on May 3, 1999.  Petitioners paid a               
          deposit of $30,087.57 as part of the purchase price.                        
               The monthly rental rate for each Crenshaw Blvd. property               
          unit was $550 in 1999.  Three of those units were occupied for 8            
          months and the fourth was occupied 6 or 7 months in 1999.                   
          Petitioners received rent of $14,700 in 1999 from the Crenshaw              
          Blvd. property tenants.                                                     








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