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residence interest". Sec. 163(h)(2)(D). "Qualified residence
interest" means interest which is paid during the year on
acquisition indebtedness or home equity indebtedness with respect
to any qualified residence of the taxpayer. Sec. 163(h)(3)(A).
A "qualified residence" may be the principal residence of the
taxpayer. Sec. 163(h)(5)(A)(i)(I).
In this case, petitioners had a mortgage on the home they
lived in. Petitioners paid "interest payments" on their
mortgage to "Retirement Account Inc., F.O.B. Allen S. Lewis IRA"
(Allen Lewis). During 1995, petitioners wrote 11 checks which
were written out to or referenced Allen Lewis and totaled
$16,425. Petitioners also had a mortgage on their home with West
Coast Bank. During 1995, petitioners wrote 32 checks for the
"interest payments" to West Coast Bank in the total amount of
$21,698.71. Petitioners claimed $3,165 of mortgage interest
expense on their 1995 return, which petitioner prepared himself.
On their 1994 return, petitioners claimed $8,450 of mortgage
interest expense. Petitioners’ 1994 return was prepared by an
accountant. While we believe that petitioners' payments did not
consist solely of interest expense, we find that a portion of
these payments must have been for mortgage interest on their
home. Although the interest portion of the payments probably was
higher than the amount claimed on the 1995 return, petitioners
did not provide sufficient evidence of the amount which was
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