Josephine Velasco - Page 2




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               The sole issue in dispute concerns the amount of commission            
          income petitioner must report as taxable income in 1996.                    
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are found                   
          accordingly.  The stipulation of facts and the exhibits submitted           
          therewith are incorporated herein by this reference.                        
               At the time petitioner filed her petition contesting                   
          respondent’s determinations, she resided in Newtown, Pennsylvania.          
               From 1990 to the year at issue, petitioner was a mortgage loan         
          officer for a bank.  From mid-1994 to 1997, petitioner also worked          
          part time as a real estate broker for the M. Riccardi Agency, owned         
          by Michael Riccardi (Mr. Riccardi).                                         
               Before November 14, 1994, petitioner and her spouse owned, and         
          occupied as their residence, property located at 227 Aspen Road,            
          Yardley, Pennsylvania (the Aspen Road property).  In 1994,                  
          petitioner and her husband encountered financial problems, and the          
          bank holding the mortgage on the Aspen Road property threatened to          
          foreclose on the property.  As a consequence thereof, petitioner            
          approached Mr. Riccardi and suggested that he purchase the Aspen            
          Road property from the bank holding the mortgage.  Mr. Riccardi             
          agreed to do so.  He made an offer to purchase the Aspen Road               
          property for $150,000; the bank rejected this offer.  Thereafter,           
          the bank foreclosed on the Aspen Road property, and the property            








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