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the years 1992, 1993, and 1994 in the amounts of $2,222, $4,392,
and $5,906, respectively.
After concessions by the parties,2 the issues for decision
are: (1) Whether petitioners are entitled to exclude from income
the receipt of certain payments for adult foster home care; and
(2) whether adult foster home care business expenses were
correctly allocated by respondent to nonexempt adult foster home
care income.
Many of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by reference. Petitioners resided in
Portland, Oregon, at the time they filed their petition in this
case.
Background
During the years 1992, 1993, and 1994, petitioners were in
the trade or business of providing adult foster home care for
individuals in Portland, Oregon.
Petitioners were licensed by the Multnomah County Aging
Services Division (ASD) as Level III adult foster home providers
and were subject to Multnomah County Administrative Rules. ASD
is an instrumentality of the State of Oregon that acts as a
2The parties agree on the amount of "other expenses" that is
deductible by petitioners. The parties agree that certain of
petitioners' claimed expenses related to their adult foster home
are subject to the rules of sec. 280A.
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