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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 each
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