Jack Chien Ching Huang - Page 8




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          Petitioner used this loan to pay down the then outstanding                  
          balance on his line of credit with Providian Bank.                          
               In September 1997, petitioner borrowed another $5,000 from             
          his mother and $3,000 from his aunt.  Petitioner used $7,540 of             
          these loans to pay down the then outstanding balance on his line            
          of credit with Providian Bank.                                              
               G.  Petitioner’s 1997 Income Tax Return                                
               Petitioner filed Form 1040, U.S. Individual Income Tax                 
          Return, for 1997.  Petitioner attached to his return a Schedule             
          C, Profit or Loss From Business, and claimed deductions for                 
          various expenses in the total amount of $77,042.  Included in               
          this amount was a deduction for rent in the amount of $14,815 and           
          a deduction for “other expenses” in the amount of $21,091.                  
               Included in the deduction for rent was $8,028, representing            
          expenses for the business use of petitioner’s home.  Included in            
          the deduction for “other expenses” was $12,540, representing the            
          repayment of principal on the loan from his line of credit with             
          Providian Bank.                                                             
               H.  Notice of Deficiency                                               
               Respondent determined a deficiency in petitioner’s income              
          tax for 1997.  In the notice of deficiency, respondent                      
          determined, inter alia, that petitioner is not entitled to any              
          deduction for an office in the home or for repayment of principal           
          on the loan from his line of credit with Providian Bank.                    






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