Douglas Ritter - Page 2

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               Respondent determined a deficiency in petitioner's 1991                
          Federal income tax in the amount of $3,845, and an addition to              
          tax under section 6651(a)(1) in the amount of $961.  The Court              
          must decide:  (1) The amount of rental income petitioner received           
          from the Broome County, New York, Department of Social Services             
          for the year 1991; (2) whether petitioner is entitled to any                
          deductions for rental expenses incurred; (3) whether petitioner             
          is entitled to three additional dependency exemptions; and                  
          (4) whether petitioner is liable for an addition to tax under               
          section 6651(a)(1) for failure to timely file a tax return.                 
               Some of the facts in the case have been stipulated and are             
          so found.  Petitioner resided in Lisle, New York, at the time he            
          filed his petition.                                                         
               For clarity and convenience, the findings of fact and                  
          opinion have been combined.                                                 
               In 1991, petitioner owned the following real property in               
          Broome County, New York:                                                    
               41 Charlotte Street, Binghamton, New York                              
               18 Pleasant Avenue, Binghamton, New York                               
               RD 2, Box 133 and 134, Conklin, New York                               
               In 1991, petitioner owned the following real property with             
          his wife, Carole Ritter, as tenants by the entireties:                      
               53 Mary Street, Binghamton, New York                                   
               99-101 Robinson Street, Binghamton, New York                           
               Langdon Grove, Kirkwood, New York                                      
               Church Road, Lisle, New York                                           







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