- 3 -
Petitioner filed his 1986 Federal income tax return on April
20, 1990.
Petitioner reported all income and deducted all expenses on
six rental properties in Philadelphia, Pennsylvania, all of which
showed a loss. Petitioner was the sole owner of four of these
properties.
Petitioner owned 4512 Kingsessing with his mother, Frances
James Moore, as tenants in common. Petitioner and his sister
Brenda Pitt owned 4514 Kingsessing as tenants in common. Both
women were on public assistance, and petitioner wanted to provide
a place for them to live. Petitioner provided the downpayment on
each property and made the mortgage and escrow payments for taxes
and insurance from his own funds. The mortgagee's records for
4512 Kingsessing are in the names of Frances James Moore or
Joseph J. James. We assume the mortgage for 4514 Kingsessing
with Brenda Pitt is similar.
Each of the Kingsessing properties consisted of three units.
Ms. Moore lived in one of the units at 4512, and Ms. Pitt lived
in a unit at 4514. The remaining units were rented to others and
managed by the two women. The women kept up the yards,
interviewed tenants, cleaned vacant apartments, collected some of
the rents on petitioner's behalf (some tenants sent their rent
directly to petitioner), paid the bills, caused repairs to be
made, and were accountable to petitioner. Ms. Moore deposited
the rental income in a special joint checking account in the
Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011