Jonathan E. Stromme and Marylou Stromme v. Commissioner

Colvin, Chief Judge:

In 2005 and 2006 three (and then four) developmental^ disabled adults lived in a house on Emil Avenue in Shoreview, Minnesota. The Emil Avenue house was owned by Marylou and Jonathan Stromme, who cared for their clients and managed the property. The local government paid them more than $250,000 in 2005 and more than $300,000 in 2006 for providing this foster care service. The Code makes these payments tax free if the clients were cared for in the Strommes’ “home”. But as discussed below the Strommes owned and resided in another home, and worked in, but did not live in, the…