In making the determination of Equitable Ownership, the Tax Court considered several key factors:
• Had the right to possess the property and to enjoy the use, rents, and profits.
• Had the duty to maintain the property.
• Was responsible for insuring the property.
• Bore the risk of loss of the property.
• Was obligated to pay taxes, assessments, and charges against the property.
• Had the right to improve the property.
• Had the right to obtain legal title to the property at any time by paying the balance of the purchase price.
