- 10 - Section 163(a) generally permits taxpayers to deduct interest paid or accrued within the taxable year on indebtedness. Sec. 1.163-1(a), Income Tax Regs.; see also Eboli v. Commissioner, 93 T.C. 123, 129 (1989). Petitioner presented no documentation to substantiate the interest deductions claimed, except for $1,010 which respondent conceded for 1979. Petitioner testified that he tried to obtain a copy of his cashed checks for 1979 and 1980 from his bank, but the bank was no longer in existence. During these years petitioner had outstanding a $25,000 loan on his sailboat and a $7,000 loan on his car. It is thus reasonable to infer that petitioner incurred interest expenses in excess of the amounts allowed by respondent in the notice of deficiency. Using our best estimate, we hold that petitioner may deduct interest of $3,200 in 1979 and $3,200 in 1980. Cohan v. Commissioner, supra. Issue 2. Unreimbursed Business Expenses Respondent determined that for 1979 and 1980, petitioner is not entitled to deduct automobile expenses, travel and entertainment expenses, and expenses incurred in connection with his boat in excess of the amounts allowed in the notice of deficiency.6 6 In the notice of deficiency, respondent allowed petitioner to deduct the following amounts: Item 1979 Amount Allowed 1980 Amount Allowed (continued...)Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
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