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indication in the record that this was an expense of any trade or
business of petitioner's. Accordingly petitioner is not entitled
to a Schedule C deduction for this interest; however, the $4,068
is deductible as an itemized deduction on Schedule A. See Smith v.
Commissioner, 84 T.C. at 898.
As to the remaining interest expenses, the record does not
show whether petitioner or some other entity took out the loans.
From the foregoing we cannot conclude that these claimed interest
expenses were petitioner's expenses; thus they are not deductible
by petitioner under section 163. These interest expenses are also
not deductible as business expense deductions under section 162,
or as bad debt deductions under section 166, even though we treat
petitioner as having paid these claimed interest expenses, and we
accept that petitioner may have been a guarantor on some or all of
the loans from which these interest expenses arose. The record in
this case simply does not provide the Court with evidence
sufficient to determine whether these interest expenses were
ordinary or necessary expenses of petitioner's trade or business,
nor does the record provide evidence sufficient to determine
whether these interest expenses were bad debts becoming worthless
during any of the years in issue. From the foregoing we conclude
that these claimed interest expenses are not deductible by
petitioner.
We hold mostly for respondent on this issue to the extent set
forth above.
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