Joseph A. Morcos and Joann M. Morcos - Page 4

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               The first floor of the main house consists of a furnished              
          living room, dining room, den, and kitchen.  The second floor               
          consists of petitioners’ private bedroom suite, a guest bedroom,            
          a guest bathroom, a laundry room, a sun porch, and an office.               
          The third floor consists of three furnished bedroom suites with             
          private baths (third floor units).  Each suite is accessed with             
          its own key.  The third floor units are accessed by climbing a              
          staircase that extends from the foyer in the first floor, to the            
          second and third floors.                                                    
               For all of 1996 and 1997, petitioners rented the three third           
          floor units on a month-to-month basis to individuals not related            
          to petitioners.  The tenants of these units had full use of the             
          facilities on the first floor and the second floor, except for              
          petitioners’ private bedroom suite.  The tenants of the main                
          house, as well as petitioners, prepared meals daily in the                  
          kitchen and used the dining area and laundry room.                          
               The carriage house is a separate dwelling unit.  It consists           
          of a living room, kitchen, and laundry room on the first floor              
          and a bedroom and bath on the second floor.  Petitioners did not            
          use any portion of the carriage house as part of their personal             
          residence or for personal purposes in 1996 and 1997.                        
               Petitioners reported income and expenses from their rental             
          of the third floor units and the carriage house on Schedules E,             
          Supplemental Income and Loss, filed with their 1996 and 1997                

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