- 10 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
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