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that are deductible under section 164(a)(1);7 i.e., that were
imposed on her interest in real property and that such taxes were
levied for the general public welfare, sec. 1.164-3(b), Income
Tax Regs. Absent that evidence, we hold that petitioner is not
entitled to the deduction that she claims.
To reflect the foregoing,
Decision will be
entered for respondent.
7 See sec. 1.164-3(b), Income Tax Regs., which defines real
property taxes as “taxes imposed on interests in real property
and levied for the general public welfare, but does not include
taxes assessed against local benefits. See �1.164-4.” Sec.
1.164-4(a), Income Tax Regs., states that taxes for local
benefits that are not deductible include taxes for benefits “such
as streets, sidewalks, and other like improvements, imposed
because of and measured by some benefit inuring directly to the
property against which the assessment is levied”. See sec.
164(c)(1).
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