Austin B. Ewell, Jr. - Page 2

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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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