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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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