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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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Last modified: May 25, 2011