This section contains the nature of the case and procedural background.

Cramer (P) sold property to Osborn under a land sale contract. Osborn eventually failed to make the property tax payments as required and also failed to make the monthly payments on the loan. P foreclosed and got repossession of the property in 1966. P also made property tax payments on her mother's property and eventually her mother gave her a quitclaim deed to the property the next year after the taxes were paid. P also purchased a new residence and paid property taxes on it and in sum total P claimed all the property tax payments as deductions. The IRS allowed the deductions for the Clearview street property as that was P's residence but denied them on her mother's property and the property that was repossessed.

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