Abarca v. Comr., T.C. Memo. 2012-245

(petitioner entered into partnerships with other persons with design to buy rental properties; petitioner not named on mortgages for purchased properties; petitioner deducted mortgage interest on properties; evidence not clear as to whether titles to properties contributed to partnerships, but evidence showed that petitioner did not hold title to any properties; partnership formalities not followed; petitioner did not account for partnership existence on either 2007 or 2008 returns, but filed returns as personal owner; interest deduction not allowed’ property tax deduction not allowed; accuracy-related penalty imposed).