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for any year before us other than for 1982.
We hold for respondent on this issue, except that we hold for
petitioner as to $200 for 1982.
(2) Interest Expense
Petitioner paid $102,994 in interest in 1982, and deducted
the entire amount on his 1982 tax return as a Schedule C
deduction, supra table 8. He also claimed Schedule C interest
expense deductions for 1983 ($33,599), 1984 ($36,058), and 1985
($24,293). He did not claim such a deduction for 1986.
Petitioner paid $1,087 interest on a loan to finance a pickup
truck, which he owned, and used for personal, law practice, Hall
Farms, and corporate business purposes. Under section 162(a)
petitioner is entitled to a Schedule C deduction for this expense
to the extent that it was an ordinary and necessary expense of his
law practice and Hall Farms. Consistent with our discussion as to
depreciation on the pickup truck we hold (and we have found) that
petitioner is entitled to deduct for 1982 on Schedule C $125 of
the claimed $1,087 interest on the debt to finance his pickup
truck. Cohan v. Commissioner, supra; Gerling International Insur.
Co. v. Commissioner, supra. The remaining $962 is deductible as an
itemized deduction on Schedule A. See secs. 1.163-1(a) and 1.266-
1(a)(1), Income Tax Regs.
Petitioner paid $4,068 interest on a loan to finance bank
stock, which was owned by petitioner and his father. There is no
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