Saffet and Ana Uslu - Page 12

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          indebtedness, if he and Aysun were ever called upon to pay the              
          indebtedness (arising from a default by petitioners), they would            
          look to petitioners for payment of whatever amounts that Haluk              
          and Aysun paid to the mortgage lender.  The Court is satisfied              
          that, should that situation ever arise, Haluk and Aysun would               
          have a cause of action against petitioners.                                 
               The Court is satisfied, from all the evidence presented,               
          that petitioners have continuously treated the Alisal property as           
          if they were the owners, and that they, exclusively, held the               
          benefits and burdens of ownership thereof.  On this record, the             
          Court holds that petitioners established equitable and beneficial           
          ownership of the Alisal property, and that they were liable to              
          Haluk and Aysun in respect of the mortgage indebtedness.  As                
          such, the Court holds that petitioners are entitled to a                    
          deduction for the $18,980 home mortgage interest paid by them               
          during 1992.                                                                

                                                 Decision will be entered            
                                             under Rule 155.                          

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