Princess Stephan Obriot - Page 6




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                                        1998                                          
                    Total Support for Ayla        Support From Petitioner             
          Rent                $1,425                   $0                             
          Utilities           396                      396                            
          Food                1,800                    1,800                          
          Clothing,                                                                   
          medical, etc.            800                 800                            
          Child care             4,040                  1,770                         
          Total               8,461                    4,766                          

               We briefly explain our conclusions below.  During 1997 and             
          1998, petitioner and Ayla lived in the house belonging to the               
          Stephans in Jonesboro, Georgia.  Petitioner occupied the                    
          partially completed basement, and Ayla occupied one of the three            
          bedrooms.  Petitioner, Ayla, and the Stephans shared use of the             
          kitchen and family room.                                                    
               The amount expended for Ayla includes one quarter of the               
          rental value of the house in which she lived.  See Reed v.                  
          Commissioner, T.C. Memo. 1980-333.  Based on the record we                  
          conclude that the fair rental value was $475 per month, or $5,700           
          per year.  The portion expended for Ayla is $1,425 for each year.           
          Petitioner did not pay rent on the allocable portion of the fair            
          market rental value of the house that she and Ayla occupied.                
               One quarter of the total water, gas, and electricity bills             
          (utility bills) is allocable to Ayla’s support.  Id.  We conclude           
          the total utility costs of the household were $1,392 in 1997 and            
          $1,583 in 1998.  Ayla’s allocable share of utility costs was $348           






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