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the Morris Street property; petitioners apparently hired resident
managers to act as the primary caregivers at the other
properties.
The State of Oregon made the following payments to
petitioners for care provided at the properties:
Location 1992 1993
Morris Street property $30,629 $21,257
117th Avenue property 28,556 27,443
Alder Street property 8,899 21,218
134th Avenue property 14,092 10,216
Petitioners took the position that all these payments were
excludable under section 131(a), and they did not report any of
the payments on their returns.
In the notice of deficiency, respondent did not contest (and
is not here contesting) the application of section 131 to the
payments received from the State of Oregon for care provided at
the Morris Street property, which is petitioners' “personal
family residence”. However, respondent determined (and urges us
to hold) that the exclusion does not apply to the payments
received for care provided at the other properties, none of which
was petitioners' personal residence. Petitioners also received
payments from private parties and from public agencies other than
the State of Oregon (e.g., the U. S. Department of Veterans
Affairs), but the tax treatment of these payments is not in
dispute.
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