David W. Chiu - Page 18

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                  The Form 1098 also indicates the amount of each monthly                                
            payment attributable to interest.  Therefore, by multiplying the                             
            percentage of each mortgage payment paid by petitioner times the                             
            interest component of the payment, one can derive the amount of                              
            interest appropriately treated as paid by petitioner, as follows:                            
            Payment Due          Interest              Petitioner's          Petitioner's                
            Date                 Component of          Percentage            Interest                    
                                 Payment                                     Payment                     
            Feb. 1,1990          $1,719.51             100%                  $1,719.51                   
            Apr. 1,1990          1,717.13              100%                  1,717.13                    
            May 1,1990           1,715.93              48.27%                828.28                      
            June 1,1990          1,714.72              50.12%                859.42                      
            July 1, 1990         2,135.29              57.28%                1,223.09                    
            Aug. 1, 1990         2,134.26              50.01%                 1,067.34                   
                                                                             $7,414.77                   
                  Therefore, using our discretion under the Cohan rule, we                               
            find that petitioner made total interest payments of $7,414.77 in                            
            1990.  Petitioner is entitled to a deduction in that amount.                                 
            Charitable Contributions                                                                     
                  The next issue for decision concerns petitioner's claimed                              
            deduction for charitable contributions, which respondent                                     
            disallowed for lack of substantiation.  On his return, petitioner                            
            claimed a deduction for gifts to charity in the amount of $2,568,                            
            of which $2,132 was listed under contributions by cash or check                              
            and $436 was listed under contributions by other than cash or                                
            check.  To substantiate the deduction, petitioner testified that                             
            the claimed contributions were donations to "church and Goodwill,                            
            stuff like that".  When questioned how he arrived at the figure                              
            of $2,568, petitioner testified that he based it on amounts                                  




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