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Cramer v. Commissioner

United States Tax Court
55 T.C. 1125 (1971)


Facts

From 1964–1966, Cramer (plaintiff) paid property taxes on three different properties. The first property was located on Auburn Street. In 1963, Cramer sold the Auburn residence to Osborn, who agreed to pay the sales price in monthly installments in addition to the property taxes. Cramer retained record title to the property. Osborn defaulted on his payments during 1964 and 1965. As a result, Cramer paid the property taxes for those years and initiated foreclosure proceedings against Osborn. She regained possession of the property on February 18, 1966. Cramer sold the residence soon after and paid the property tax for that year as well. The second property was located on Atkinson Street. It belonged to Cramer’s ailing mother. Beginning in 1965, Cramer’s mother was hospitalized from time to time. During this period, Cramer took care of the Atkinson residence, paying the property taxes for 1965 and 1966 with her own money. In 1967, Cramer’s mother transferred title to the residence to Cramer. The third property was located on Clearview Street, which Cramer purchased shortly after selling her Auburn residence in 1963. She paid property taxes on the residence in 1964, 1965, and 1966. Cramer deducted her property tax expenditures on all three residences from 1964–1966. The Commissioner disputed the deductions.

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Holding and Reasoning (Featherston, J.)

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