Ronna Joan Robertson - Page 7




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               More important, however, is the fact that all of the checks            
          submitted by petitioner were issued from a joint bank account.              
          Petitioner has failed to produce any evidence describing the                
          contributions or deposits made by petitioner, petitioner’s                  
          mother, and petitioner’s sister to the joint bank account.  Thus,           
          it is unclear which of the joint account holders actually paid              
          for these medical expenses.  Accordingly, petitioner has not                
          shown entitlement to medical and dental deductions for 1993 or              
          1994.                                                                       
               B.  Real Property Taxes                                                
               Section 164(a)(1) provides that taxpayers are entitled to a            
          deduction for real property taxes paid during the taxable year.             
          During 1993 and 1994, petitioner resided in and owned a home at             
          318 Georgia Circle, Placentia, California,5 and paid real                   
          property taxes of $1,866.81 and $1,910.13 in 1993 and 1994,                 
          respectively.  Accordingly, petitioner is entitled to deduct                
          these amounts as real property taxes on her 1993 and 1994 Federal           
          income tax returns.                                                         
               C.  Personal Property Taxes                                            
               Section 164(a)(2) permits deductions for State and local               
          property taxes.  Under section 164(b)(1), property taxes are                



               5 Respondent states in his brief that this house was jointly           
          owned by petitioner and other members of petitioner’s immediate             
          family, including her sisters and mother.  There is no evidence             
          of this in the record, however.                                             





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