Richard B. May and Jane M. May - Page 4

                                        - 3 -                                         
               At the time that the petition was filed, petitioners resided           
          in Buffalo, New York.                                                       
               During the years in issue, petitioner worked for the City of           
          Buffalo as a court advocate in a program known as Hispanics                 
          United of Buffalo.  In his civil service job, petitioner worked             
          approximately 28-30 hours per week.  Petitioner Jane M. May (Mrs.           
          May) worked as a full-time teacher for the Buffalo Board of                 
          Education.                                                                  
               Since 1974, petitioner has been buying, selling, renting,              
          and managing real estate properties.3  At the beginning of 1996,            
          he owned 18 doubles consisting of 36 rental units, two lots, and            
          three garages in North Buffalo, New York.4  (These properties are           
          collectively referred to as the rental properties.)  By the end             
          of 1996, he had sold two of the doubles.  During the years in               
          issue, he rented approximately 30 of the units to tenants with              
          special needs, e.g., handicapped people, senior citizens, and               
          people receiving social services, and he rented the remaining               
          units to other tenants.  Petitioner personally manages the rental           
          properties, which includes finding tenants for the units,                   
          collecting and depositing rent, making the mortgage payments, and           
          inspecting the units.  Although petitioner makes minor repairs,             

               3  On the basis of the record, it appears that Mrs. May was            
          not involved in petitioner’s real estate activities.                        
               4  “Doubles” are residential duplexes with units situated on           
          the ground and second levels.                                               





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