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petitioner made to the property show a "For Sale" sign in the
window of the property. A classified advertisement that was
introduced at trial likewise indicates that the property was for
sale, not for rent.
Petitioner also introduced numerous receipts in an attempt
to substantiate purchases of items for supplies and repairs. The
majority of these receipts show purchases in the Washington,
D.C., area, not in the Pittsburgh area. That petitioner would
purchase all of these items in the Washington, D.C., area and
transport them to Pittsburgh to make the repairs is not credible,
especially in light of petitioner's testimony that a family
friend in Pittsburgh made most of the repairs.
On the record before us, we cannot conclude that petitioner
attempted to rent the Pennsylvania property. We conclude that
petitioner did not hold out the Pennsylvania property in the
course of a trade or business or for the production of income
during 1991. Thus, respondent's determination that petitioner is
not entitled to deductions relating to the property, in excess of
the real property taxes allowed, will be sustained.
Personal Exemptions for Petitioner's Parents and
Head of Household Filing Status
Respondent determined that petitioner is not entitled to
personal exemptions for petitioner's mother, father, and brother
for 1991. At trial, petitioner conceded that he was not entitled
to a personal exemption for his brother.
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