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names of herself and petitioner. She wrote checks for expenses,
including some checks to "cash".
During the year in issue, petitioner lived at the West
Hortter property until October 1986, when he moved to Texas. The
property was then converted to rental property. Also in the fall
of 1986, petitioner's mother and sister moved to his property at
10 Church Road, where they continue to reside and to pay rent.
They continued to manage petitioner's properties at Kingsessing
and his other properties as well.
On his Federal income tax return, petitioner reported all of
the rental income and claimed all of the expenses associated with
the Kingsessing properties. Neither Ms. Moore nor Ms. Pitt filed
a Federal income tax return for 1986.
In the notice of deficiency, respondent allowed all the
amounts claimed for the property on North Walnut Street. She
disallowed 50 percent of the expenses claimed on the Kingsessing
Avenue properties, on the theory that petitioner had only a 50-
percent interest. Some other expenses for those and the
remaining properties were disallowed for lack of substantiation.
Respondent made concessions in the stipulation and on brief, with
regard to items substantiated by petitioner close to or at time
of trial.
The chart below reflects total substantiated expenses:
Description 4512 4514 400 West Week 17 10 Church
Kingsessing Kingsessing Hortter Unit 316 Road
Auto Expense -- -- -- -- --
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Last modified: May 25, 2011