Peter Milton Joseph and Ella Joseph, Deceased - Page 11

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          this case, we conclude that petitioners have failed to provide              
          any substantiation to support any claimed deduction for real                
          estate tax paid on their Bahamas property.                                  
               Petitioners also owned two pieces of property located in               
          Punta Gorda, Florida.  Petitioner testified that petitioners paid           
          real estate taxes on these properties and claimed the taxes paid            
          as a portion of the deduction claimed for real estate taxes on              
          their Schedule A.  However, petitioner again did not testify to             
          the specific amounts of the taxes paid on the Florida properties.           
          The only corroborating evidence in the record, which petitioner             
          alleges shows that taxes were paid on these properties, is a                
          Statement of Annual Maintenance Assessment in the amount of                 
          $96.43.  Respondent reported, at trial, that the $1,017 portion             
          allowed by respondent, pursuant to section 164, of petitioners’             
          claimed Schedule A deduction for real estate taxes, consisted of            
          real estate taxes paid in respect to the Florida properties.                
          However, it is not clear from the record if the amount of the               
          Annual Maintenance Assessment has already been included in the              
          $1,017 allowed by respondent or if such amount is considered a              
          tax.                                                                        
               Based on the foregoing, we conclude that petitioners have              
          failed to provide any substantiation to support any claimed                 
          deduction for real estate taxes paid on their Florida properties            
          in excess of the $1,017 allowed by respondent.                              






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