Gabriel M. Daya, et al. - Page 24




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          issue to show the value of the Mahmoud Daya family’s lodging.  The          
          value of a claimed dependent’s lodging must be included as part of          
          his total support; it is well settled, however, that the proper             
          measure for valuing lodging for purposes of determining support is          
          the fair rental value of the premises allocable to the claimed              
          dependent and not the actual mortgage payments and property taxes           
          paid for maintaining the household.  See Pierce v. Commissioner,            
          66 T.C. 840, 849 (1976); Blarek v. Commissioner, 23 T.C. 1037,              
          1039 (1955); Keegan v. Commissioner, T.C. Memo. 1997-511; Pierce            
          v. Commissioner, T.C. Memo. 1981-254; Gilliam v. Commissioner,              
          T.C. Memo. 1969-188, affd. per curiam 429 F.2d 570 (4th Cir.                
          1970); Tourte v. Commissioner, T.C. Memo. 1969-143; Sumner v.               
          Commissioner, T.C. Memo. 1969-156; Coary v. Commissioner, T.C.              
          Memo. 1969-25; sec. 1.152-1(a)(2)(i), Income Tax Regs.                      
          Petitioners have not provided any evidence from which we could              
          conclude that the mortgage payments and property taxes are in any           
          way related to the fair rental value of the Foster City residence.          
          See Coary v. Commissioner, supra.  Without evidence of the fair             
          rental value of the residence, Gabriel cannot establish Mahmoud’s           
          total support.  See Sumner v. Commissioner, supra; Coary v.                 
          Commissioner, supra.                                                        
               Petitioners assume they should be credited with supplying the          
          Mahmoud Daya family’s lodging during the years in issue, but it is          
          the owner of the premises who is to be credited with providing the          






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