Joseph J. James - Page 5

                                                                      - 5 -                                                                           

                          Clean & Maint.     $83          $45          --        $229          --                                                     
                          Insurance          776          198          $72        --          $130                                                    
                          Interest         3,373        6,380          330        600        2,309                                                    
                          Repairs            198          355          391         --          200                                                    
                          Taxes              601          601           84         --          429                                                    
                          Utilities           --          187           13         --           --                                                    
                          PMI                 67          266           --         --          126                                                    
                          Other               70           30           87         --           24                                                    
                          sub-total        5,168        8,062          977        829        3,218                                                    
                          Depreciation       449        2,209          365        461        3,625                                                    
                          Total            5,617       10,271        1,342      1,290        6,843                                                    






                                                                    OPINION                                                                           

                          As a general rule, herein applicable, the taxpayer has the                                                                  

                 burden of proving that the Commissioner erred in her                                                                                 

                 determinations.  Rule 142(a).                                                                                                        

                 Substantiation of Rental Expenses                                                                                                    

                          In the stipulation of facts and in respondent's brief,                                                                      

                 respondent conceded numerous deductions.                                                                                             

                          In addition, petitioner submitted a number of illegible                                                                     

                 receipts and slips of paper with handwritten itemizations and                                                                        

                 totals but without supporting documents.  Other documents                                                                            

                 submitted were duplications of amounts that had already been                                                                         

                 allowed or stipulated.  Some were undated receipts, were for                                                                         

                 years not in issue, or did not reveal for which property work was                                                                    

                 done or what work was done.  However, based upon the testimony of                                                                    

                 witnesses and some documents, we find that petitioner has                                                                            

                 substantiated these additional items:                                                                                                

                          4512 Kingsessing - Repairs of $198, consisting of paint                                                                     

                 ($40) and window guards ($158); and "other" of $70, consisting of                                                                    











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