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petitioners are entitled to take a deduction for real estate
taxes; and (3) whether petitioners are entitled to deduct
mortgage interest.
Some of the facts have been stipulated and are so found.
The stipulation of facts is incorporated herein by this
reference. At the time the petition was filed, petitioners
resided in Baltimore, Maryland.
Background
Immediately before moving to Baltimore, Maryland,
petitioners resided in Shelby County, Tennessee. Petitioners
owned two quarter horses and a pony, which they paid to have
boarded at local stables. Their daughters were experienced
riders with trophies earned from competition. Petitioners also
claim to jointly own a house at 4429 Kerwin Drive in Shelby
County, Tennessee, with Mrs. Hudnall's mother, who is also their
tax adviser.
Sometime shortly before 1993, petitioners moved to
Baltimore, Maryland. They rented a dilapidated farm at 315 East
Jarrettsville Road, where, after renovation, they lived and kept
their horses without paying others to care for them. The 68-acre
farm has since been subdivided and developed into town houses.
Petitioners state that, initially, they were not aware of the
owner's plans to subdivide the property, though they admit it was
common knowledge to at least some of the neighbors. In 1994,
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