- 232 - respect to amounts of such loans, dates of such loans, interest rates, or payment schedules. Since petitioner has failed to establish that $96,254.78 or any portion of the $125,000 paid to Diesel Power on December 30, 1975, is interest expense, the deduction is not allowed. For the years 1975 and 1977, petitioner deducted interest expenses in the amounts of $2,049.04 and $688.32, respectively. Neither payment can be identified. Therefore, petitioner has failed to meet his burden of proof with respect to these amounts, and the deductions are disallowed. For the year 1976 petitioner deducted $24,400.87 paid to W.P. Glass on June 1, 1976, as interest expense. This amount was recorded in CTC's cash disbursements journal as an interest payment for a ranch. However, the entry in this journal is not accurate. In fact, the payment of $24,400.87 to Mr. Glass was for the acquisition of real estate, a ranch purchased as an asset of the A-Z Ranch Partnership. Petitioner admits that the payment to Mr. Glass was a portion of the purchase price of real property that was an asset of the partnership. Thus, this amount does not constitute interest expense. Sec. 163. For the years 1979, 1980, and 1981 petitioner claimed interest expenses paid to the Mirhosseini family in the amounts of $15,000, $44,879, and $36,000, respectively. On or about September 10, 1979, three members of the Mirhosseini family eachPage: Previous 222 223 224 225 226 227 228 229 230 231 232 233 234 235 236 237 238 239 240 241 Next
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