- 130 - For the year 1975 petitioner claimed an interest expense paid to Diesel Power in the amount of $137,500.17 on his original income tax return. Petitioner's amended tax return for 1975 reduced the interest expense paid to Diesel Power by $41,245.39. On December 30, 1975, petitioner paid Diesel Power $125,000. This amount is listed in CTC's cash disbursements journal under the transfer column; it is noted as "interest on loan" drawn by petitioner. In 1978 his accountant listed this payment as a transfer. Petitioner did not introduce into evidence any notes or other loan documents evidencing a debtor-creditor relationship between himself and Diesel Power. Testimony presented at trial with respect to moneys borrowed by petitioner from Diesel Power was not specific with respect to the amounts of such alleged loans, dates of such loans, interest rates, or repayment schedules. Therefore, petitioner is not entitled to any interest deduction in 1975 for the amount paid to Diesel Power in 1975. On June 1, 1976, petitioner paid W.P. Glass $24,400.87. This amount was deducted as interest expense. This payment was for the purchase of real estate for the A-Z Ranch Partnership. Therefore, it is not deductible as interest expense. In 1976 petitioner made three payments to Crown Life Insurance totaling $178.80. In 1976 he deducted $219.80 asPage: Previous 120 121 122 123 124 125 126 127 128 129 130 131 132 133 134 135 136 137 138 139 Next
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