Jordon Jay Fingar - Page 6

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               Sometime in 1980 petitioner, Greenbaum, and Dickey, another            
          attorney, formed the new law firm known as Dickey, Greenbaum &              
          Fingar (Dickey Greenbaum).  Dickey Greenbaum was located in a               
          downtown office space selected by the bank and close to it.                 


          The Blue Chip                                                               
               In 1976, petitioner purchased the Blue Chip (Blue Chip or              
          the boat), a year-old, 37-foot sailboat for $29,000.  Petitioner            
          paid $5,000 in cash and financed the rest at an interest rate of            
          9� percent.  During the taxable years in issue, petitioner used             
          the boat to entertain clients.                                              
                                       OPINION                                        
               At the outset, we note that the recordkeeping by petitioner            
          for the years in issue was inconsistent and disorganized.  While            
          we found petitioner generally to be a credible witness, his lack            
          of consistent recordkeeping and his disorganized presentation at            
          trial caused the Court much additional effort in reviewing the              
          record and sorting out the issues.  Thus, the responsibility for            
          any omissions in the record lies with petitioner.  Given that               
          petitioner has the burden of proof, such omissions weigh against            
          him.                                                                        
          Issue 1.  Schedule A Deductions                                             
               Respondent determined that for 1979 and 1980, petitioner is            
          not entitled to deduct taxes and interest in excess of the                  






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