Craig V. Adams - Page 10

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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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