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years. This is unlikely, given that petitioner reported income
for 1979 and 1980 of $99,558 and $89,779, respectively. It is
reasonable to infer, however, that petitioner made purchases in
connection with his boat and car, and for other miscellaneous
items. Accordingly, we hold that petitioner may deduct general
sales tax of $1,000 for 1979 and $1,000 for 1980. Cohan v.
Commissioner, supra.
For 1979, respondent concedes that petitioner paid New York
State income taxes of $4,188. For 1980, respondent did not allow
petitioner to deduct any State income taxes, because he failed to
substantiate that he incurred such expenditures. Petitioner
testified, however, that he paid State and local income taxes for
1980 but was unable to get a copy of his cashed checks because
the bank he had used went out of business. Given that
petitioner's income did not substantially fluctuate from 1979 to
1980, it is reasonable to infer that petitioner paid
approximately the same amount of State income taxes in 1980 as he
did in 1979. Accordingly, we allow petitioner to deduct $4,000
in State income taxes for 1980.
B. Interest
Respondent determined that petitioner is entitled to deduct
interest of $1,010 and zero for 1979 and 1980, respectively.
Petitioner deducted interest of $7,200 for 1979 and $10,000 for
1980.
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