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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 as
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