Pavel Dobra and Ana Dobra - Page 3

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               All of the facts have been stipulated.  The stipulation of             
          facts and the exhibits are incorporated herein by this                      
          reference.Factual Background                                                
               During the tax years in issue--1992 and 1993--petitioners              
          owned four residential properties in Portland, Oregon.2  The                
          addresses of these properties were:                                         
               1.  16001 NE Morris Street (the Morris Street property);               
               2.  1819 SE 117th Avenue (117th Avenue property);                      
               3.  11847 SE Alder Street (Alder Street property); and                 
               4.  4125 SE 134th Avenue (134th Avenue property)                       
          (collectively, the properties).                                             
               The parties have stipulated that the Morris Street property            
          was petitioners' “personal residence” and “personal family                  
          residence” during the years at issue.  The record contains no               
          information about petitioners' residential relationship to the              
          other properties.                                                           
               During 1992 and 1993, petitioners used the properties to               
          provide residential care to adults.  Five adult individuals                 
          received care at each of the properties, for a total of 20                  
          individuals being cared for at any one time.  The parties' briefs           
          indicate that petitioners provided such care personally only at             


               2 Ordinarily, we would refer to these properties as either             
          "houses" or "homes".  However, this case requires us to determine           
          the meaning of petitioners' "home", for purposes of sec. 131.               
          Therefore, we use the neutral term "properties".                            




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