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Revenue Ruling 79-180

1979-1 C.B. 95 (1979)

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Revenue Ruling 79-180

Internal Revenue Service
1979-1 C.B. 95 (1979)

JR

Facts

The Internal Revenue Service issued a revenue ruling to clarify if renters in New York could deduct newly recharacterized tax payments on their federal income-tax returns. In 1978, the New York Real Property Tax Law (the NY tax law) was amended to state that certain residential renters had an interest in their rental properties and could be personally liable for the real property taxes due. The NY tax law required the renter to make two payments to the property owner each month, one for the rent and one for the real property tax. The NY tax law also provided that renters were entitled to make deductions on their federal income-tax returns based on those taxes paid. The NY tax law did not, however, relieve the property owner of the responsibility of ensuring that all the taxes were paid and required the property owner to apply the first money received from the renter each month to the taxes. Further, if a renter did not make the property-tax payment or if the rental property was vacant, it was deemed that the property owner assumed the renter’s interest in the property and still was responsible for the taxes.

Rule of Law

Issue

Holding and Reasoning ()

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Federal Income Tax

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