Diane and Frank Burkley - Page 7




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                                      Background                                       
               Some of the facts have been stipulated and are so found.                
          The stipulation of facts and the attached exhibits are                       
          incorporated herein by this reference.                                       
               Petitioners resided in Chicago, Illinois, on the date the               
          petition was filed.                                                          
               During the year in issue, Mrs. Burkley was employed as a                
          nurse at the University of Illinois, Gentivia Certified                      
          Healthcare, and Nursepower Services.  Petitioner Frank Burkley               
          (Mr. Burkley) was employed at Genetivia Certified Healthcare.                
               At the start of 2002, petitioners owned a single-family                 
          residence located on South Green Street in Chicago, Illinois (the            
          South Green Street property).  In April 2002, petitioners                    
          purchased a multiunit apartment building located on South Vernon             
          Avenue in Chicago, Illinois (the South Vernon Avenue property).              
               The South Vernon Avenue property consists of three floors.              
          Each of the floors contains an apartment with a living room, two             
          bedrooms, a kitchen, and a sun porch.  Petitioners moved into the            
          first floor apartment of the South Vernon Avenue property in                 
          August 2002.  At the time of their occupancy, a tenant resided in            
          the second floor apartment.  Petitioners evicted this tenant in              
          August 2002 for failure to pay rent.                                         
               Petitioners rented out the second floor apartment starting              
          in September 2002 for $500 a month.  Petitioners rented out the              







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