Jordon Jay Fingar - Page 10

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               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...)           



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