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deduct the loan origination fees5 as well as the mortgage
interest, subject to substantiation. Secs. 280A(d)(1) and (2),
267(c)(4). Respondent further argues that the Dickersons have
not substantiated the claimed deductions and therefore are not
entitled to them. Petitioners provided a U.S. Department of
Housing and Urban Development Settlement Statement (settlement
statement) which substantiates that petitioners paid $2,199 in
loan origination fees as well as some amount of interest. If the
record provides sufficient evidence that the Dickersons paid the
mortgage interest, but they are unable to prove the exact amount,
we can estimate the amount of the payments. Cohan v.
Commissioner, 39 F.2d 540, 544 (2d Cir. 1930). In order for the
Court to make such an estimate, we must have some basis in fact
upon which an estimate may be made. Vanicek v. Commissioner, 85
T.C. 731, 743 (1985). Without such a basis, any allowance would
amount to unguided largesse. Williams v. United States, 245 F.2d
559, 560 (5th Cir. 1957). Mrs. Dickerson testified that the
Dickersons paid the mortgage on the Green Ridge residence.
Although we cannot determine the exact amount of interest paid by
the Dickersons, we conclude that, based on Mrs. Dickerson's
testimony and the settlement statement, it was at least as much
as claimed on their Schedule A, and therefore we hold that they
5 The loan origination fees are deductible ratably, over
the life of the loan. Sec. 461(g)(1); cf. Huntsman v.
Commissioner, 91 T.C. 917, 920 (1988), revd. 905 F.2d 1182 (8th
Cir. 1990).
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