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forth various factors to consider. Sec. 1.183-2(b), Income Tax
Regs.
On this record, we must conclude that petitioner did not
engage in his apartment house activity in 1991 for profit within
the meaning of sections 162, 212, or 183.
We turn to section 183(b) which provides in pertinent part
that in the case of an activity which is not for profit, the
deductions allowable are those allowable "without regard to
whether or not such activity is engaged in for profit."
Respondent has agreed that petitioner substantiated $1,849 of
mortgage interest paid in 1991, and that this amount is
deductible under section 163 without regard to whether the
activity is engaged in for profit and is to be added to his
itemized deductions. Sec. 183(b). Except for this amount,
respondent is sustained on this issue.
Respondent also disallowed $1,180 claimed as New York City
mortgage recording tax and transfer tax on petitioner's Schedule
A. These taxes related to the purchase of the apartment house.
We have concluded that the apartment house is not an activity
engaged in for profit. These expenses are not currently
deductible. Sec. 183(b).
Respondent also disallowed a claimed charitable deduction
of $1,534. At trial, respondent maintained that petitioner had
not substantiated any charitable contributions. Petitioner
claimed he had a "little notebook" in which he recorded
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