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because petitioner and his former spouse first had a divorce or
separation instrument on December 19, 1987.
2. Whether petitioner may deduct $72,024 for interest and
$10,727 for taxes that he paid, on behalf of his former spouse,
as petitioner contends; $10,002, as respondent contends; or some
other amount. We hold that he may deduct a portion of these
expenses equal to the portion he proved he paid with his separate
funds.
3. Whether petitioner may deduct $6,326 for business use
of his Jeep Cherokee. We hold that he may not.
Section references are to the Internal Revenue Code in
effect for the year in issue. Unless otherwise stated, Rule
references are to the Tax Court Rules of Practice and Procedure.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
A. Petitioner
Petitioner lived in Fresno, California, when he filed his
petition. He is a lawyer. He represented public water districts
and some farmers and ranchers. He used the cash receipts and
disbursements method of accounting.
B. Real Property Belonging to Petitioner and His Former Spouse
In 1987, petitioner and his former spouse jointly owned the
following property:
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