Lloyd Patterson - Page 2

               Respondent determined a deficiency in petitioner's Federal             
          income tax for the year 1991 in the amount of $4,377, and an                
          addition to tax under section 6651(a) in the amount of $339.                
               After concessions, the Court must decide:  (1) Whether                 
          petitioner is entitled to any deductions with respect to his                
          purported rental activity; (2) whether petitioner is entitled to            
          deduct any amount for charitable contributions; and (3) whether             
          petitioner is subject to limitations under section 219(g) on the            
          deduction of an Individual Retirement Account contribution.                 
               Some of the facts have been stipulated and are so found.               
          Petitioner resided in Brooklyn, New York, when his petition was             
          filed.  For convenience and clarity, the findings of fact and               
          opinion are combined.                                                       
               Petitioner failed to file timely his 1991 Federal Income Tax           
          return.  After the issuance of the notice of deficiency,                    
          petitioner submitted an executed Form 1040 for the taxable year             
          1991 to the Brookhaven Service Center on February 8, 1994.  His             
          filing status was married filing separate.                                  
               Petitioner reported $26,000 of wage income and $2,517 of               
          interest income on his return.  He claimed Schedule A deductions            
          for taxes and charitable contributions.  He also claimed a                  
          Schedule E loss in the amount of $4,795 relating to a purported             
          rental property.                                                            
               Petitioner testified that he bought an apartment house in              
          Brooklyn, New York, in July 1991.  Respondent agreed that                   

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