Valerie Jean Genck - Page 11

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          Rule 155 computation in accordance with the appropriate section             
          168(e) classification.                                                      
          Interest                                                                    
               Petitioner claimed a deduction for interest paid in the                
          amount of $1,880.  The interest claimed consists of:  (1) One-              
          half of the interest paid during 1992 on petitioner's credit card           
          debt, and (2) interest paid during 1992 on a loan obtained by               
          petitioner to pay for studio recording time.                                
               Section 163(a) provides that there shall be allowed as a               
          deduction all interest paid or accrued within the taxable year on           
          indebtedness.  However, section 163(h)(1) generally disallows any           
          deduction for personal interest paid or accrued during the                  
          taxable year.  Although petitioner testified that she used her              
          credit cards for both business and personal expenses, we accept             
          her estimate that 50 percent of her credit card interest was paid           
          on debt incurred for business purposes, based upon her credible             
          testimony.  Since the interest paid on the debt incurred to pay             
          for studio recording time is directly related to petitioner's               
          business, we hold that she is entitled to her claimed deduction             
          for interest expense.                                                       
          Rental of Recording Studio                                                  
               Petitioner claimed a deduction for rental of business                  
          property in the amount of $2,169.33.  The amount claimed includes           
          $1,200 paid as rent for the home office, discussed supra, and               






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Last modified: May 25, 2011