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Based upon substantiation submitted by petitioner at trial, we
have determined the expenses paid with respect to these
properties to be as follows:
53 Mary Street: $4,318.87
99-101 Robinson Street: $5,178.72
18 Pleasant Avenue: $712.11
RD 2, Box 133 and Box 134: $576.17
As outlined above, these substantiated expenses consist of
utilities, trash removal, and real property taxes paid during
1991. Because petitioner jointly owned both the 53 Mary Street
and 99-101 Robinson Street properties with Mrs. Ritter, he is
only entitled to deduct half of the utility and trash removal
expenses for those properties. White v. Commissioner, 18 T.C.
385 (1952). Although the payment of real property taxes by a co-
owner has been treated differently than the payment of other
expenses, the threshold requirement for allowing a co-owner to
deduct 100 percent of the property taxes paid is that the co-
owner must have paid the taxes with his separate funds. Higgins
v. Commissioner, 16 T.C. 140 (1951); Powell v. Commissioner, T.C.
Memo. 1967-32.
In this case, we find that Mrs. Ritter made the half of the
property tax payments with her own money; i.e., the rents
petitioner collected on her behalf. Thus, petitioner only paid
one-half of the property taxes on the jointly owned rental
properties. Accordingly, we find that petitioner is entitled to
deduct one-half of the expenses paid for the 53 Mary Street and
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