Peter Milton Joseph and Ella Joseph, Deceased - Page 12

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               Petitioners further owned property in Chicago, Illinois,               
          which was their principal residence.  This property was located             
          on two adjoining tracts of land.  Petitioner testified that the             
          real estate taxes on this property were paid through petitioners’           
          mortgage loan with EMC Mortgage Corporation.  Petitioner offered            
          into evidence a monthly billing statement dated December 16,                
          1999, from EMC Mortgage Corporation, along with a 1997 annual               
          billing statement to corroborate his testimony.  Both documents             
          were received into evidence by the Court.  Petitioner testified             
          that the taxes paid in 1999 were approximately similar to the               
          taxes paid in 1997.  The monthly billing statement reflects four            
          instances of “County Tax Payments” during taxable year 1999;                
          September 8, October 7, October 11, and December 17, in the                 
          amounts of $368.45, $381.59, $798.97, and $381.59, respectively.            
          The monthly billing statement reflects total real estate taxes              
          paid during taxable year 1999 in the amount of $1,930.60.                   
          Petitioner testified that the reason for several individual                 
          payments of tax was due to the fact that the property was located           
          on two tracts of land and the taxes were assessed per tract.  The           
          1997 annual billing statement reflected two total tax amounts,              
          one for each separate tract of land, in the amounts of $736.89              
          and $736.89.  The 1997 annual billing statement reflected a total           
          of real estate taxes paid in the amount of $1,473.78.                       







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