A municipal rent control ordinance allowed landlords to charge real property tax increases to the tenants as a monthly “tax surcharge.” The ordinance stated that the surcharge was not to be considered rent for purposes of computing cost-of-living rental increases. The IRS ruled that the tenant may not deduct the “tax surcharge” as a property tax. The tax is imposed on the landlord, not on the tenant. The city ordinance, which permitted the landlord to pass on the tax increases to a tenant, did not shift liability for the property taxes from the landlord to the tenant. For federal tax purposes, the surcharge is merely an additional rental payment by the tenant. Similarly, “rates tax” or “renters’ tax” imposed on tenants was ruled to be nondeductible because the tax is imposed on the person using the property rather than the property itself.