- 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 thePage: Previous 1 2 3 4 5 6 7 8 9 10 Next
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