John N. Shelton, Jr. - Page 5




                                         -4-                                          
          residential rental property located at 3313 Taney Road,                     
          Baltimore, Maryland.  The property consists of a two-story                  
          shingle house with a driveway.  There is an apartment on each               
          floor.  Petitioner purchased the property in September 1985 and             
          paid $47,764.95 for the dwelling and land.                                  
               During the years at issue, petitioner rented the first floor           
          apartment to Mr. and Mrs. Lewis Reavis.  During 1994 and 1995 the           
          Reavises paid $200 per month rent.  During 1996 and 1997 the                
          Reavises paid $250 per month rent.  Petitioner paid for all                 
          utilities.  The second floor apartment has been vacant for some             
          time.  When both apartments were rented in 1993, petitioner                 
          received about $5,000 in rent.                                              
               At trial the Court received into evidence four Schedules E,            
          Supplemental Income and Loss, one for each taxable year in issue,           
          prepared by petitioner for purposes of trial, reconstructing the            
          rents received, and expenses relating to the Taney Road property.           
          The schedules are summarized below:                                         
                            Taxable Year                                              
          1994       1995         1996        1997                                    
          Rental income                   $2,400     $2,400      $ 3,000      $3,000  
          Expenses:                                                                   
          Insurance                        458        460          510         510    
          Mortgage interest              9,935     10,396        9,953       9,683    
          Repairs                        1,175        675        1,275       3,494    
          Supplies                        -0-       3,602          645         887    
          Taxes                          1,781      1,844        2,078       4,363    
          Utilities                      1,803      2,125        2,036       1,912    
          Total expenses              15,152     19,102       16,497      20,849      
          Add:  Depreciation          1,737      1,737        1,737       1,737       
          Total expenses              16,889     20,839       18,234      22,586      
          Losses from real estate      (14,489)   (18,439)     (15,234)    (19,586)   






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