- 2 - properties that were not their family residence. Accordingly, we sustain R's determination that the payments received from State O for care provided at those three properties were not excluded from gross income under sec. 131(a), I.R.C. Paul A. Stamnes, for petitioners. Wesley F. McNamara, for respondent. OPINION BEGHE, Judge: Respondent determined deficiencies of $20,692 and $24,180 in petitioners' Federal income tax for 1992 and 1993, respectively. The only issue for decision is whether payments received by petitioners from the State of Oregon are to be excluded from petitioners' income under section 131(a) as "qualified foster care payments".1 To resolve this issue we must answer a question of first impression: whether a house that is not the foster care provider's residence may constitute "the foster care provider's home" for purposes of section 131(b)(1)(B). Petitioners Pavel Dobra and Ana Dobra, husband and wife (petitioners), resided in Portland, Oregon, at the time the petition was filed. 1 All section references are to the Internal Revenue Code in effect during the years at issue, and all Rule references are to the Tax Court Rules of Practice and Procedure, unless otherwise specified.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
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