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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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