Joseph J. James - Page 6

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          a certificate of occupancy fee ($30) and newspaper advertising              
               4514 Kingsessing - Repairs of $355.  We estimate this amount           
          based on testimony and some written records.  See Cohan v.                  
          Commissioner, 39 F.2d 540 (2d Cir. 1930).  We also allow                    
          utilities of $187, based on electric bills for public lighting              
          for the common area.  We disregard other electric bills at this             
          address, because they pertain to Ms. Pitt's personal living                 
               10 Church Road - Repairs of $200.  See id.                             
               400 W. Hortter - Repairs of $391, consisting of expenses for           
          a refrigerator.  Although the receipt was in the tenant's name,             
          we are satisfied by the testimony, and by the fact that the                 
          receipt was in petitioner's possession, that it was a legitimate            
          rental expense.                                                             
               We sustain respondent's determinations as to depreciation.             
          Ownership of Rental Properties--4512 and 4514 Kingsessing                   
               Although the amounts set out above have been substantiated,            
          respondent contends that petitioner's deductions pertaining                 
          thereto should be limited to 50 percent.  The properties at 4512            
          and 4514 Kingsessing are owned by petitioner and his mother and             
          sister, respectively, as cotenants.  Petitioner argues that,                
          since he purchased the properties with his own funds and paid all           
          the expenses connected therewith, he should be entitled to claim            

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