Wayne and June Ellen Hairston - Page 22

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          homeowner's insurance attributable to petitioners' home office,             
          renter's insurance attributable to petitioners' home office, and            
          hazard insurance on petitioners' residence, and mortgage                    
          insurance.  However, petitioners failed to introduce any evidence           
          showing that they are entitled to a larger deduction than the               
          amount allowed by respondent.  Consequently, petitioners have not           
          met their burden of proof, and we sustain respondent with respect           
          to this issue.                                                              
               Interest Expenses for 1990                                             
               For the taxable year 1990 petitioners deducted "other                  
          interest" in the amount of $1,130.  Of this amount, respondent              
          disallowed $282.  Although petitioners, on brief, explain that              
          the interest deducted is attributable to vehicles used in their             
          business, they failed to introduce any evidence that they are               
          entitled to a larger deduction than the amount allowed by                   
          respondent.  See Rule 143(b).  Consequently, petitioners have not           
          met their burden of proof, and we sustain respondent with respect           
          to this issue.                                                              
          Issue 4.  Section 6653(a)(1) Addition to Tax for Negligence for             
          1988                                                                        
               Respondent determined an addition to tax for negligence                
          under section 6653(a)(1) against petitioners for their 1988                 
          taxable year.  For that year, section 6653(a)(1) imposes an                 
          addition to tax equal to 5 percent of the underpayment of the tax           
          required to be shown on a taxpayer's return if any part of that             





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