Allie Ray McCullen and Shurley G. McCullen - Page 17

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          C.   Whether Petitioners May Deduct the Interest That They                  
               Claimed on Their Schedules F as Farm-Related Interest                  
               1.   Whether the Interest Was Related to Farming                       
               Respondent points out that petitioners commingled funds and            
          did not keep accurate records.  Respondent contends that                    
          petitioners have not shown that the interest that they deducted             
          on their Schedules F for 1990 related to farming.  We disagree.             
               Petitioner credibly testified that he used his loans from              
          New-East Bank, Bank of Stanley, Southern National Bank, and First           
          Citizens Bank for his farm operations.  Thus, we hold that                  
          petitioners properly deducted the interest remaining at issue               
          that they paid to those banks for farm interest.  Petitioners may           
          not deduct as farm interest the interest they paid to First                 
          Hanover Bank because petitioners have not shown that they used              
          the loans from First Hanover Bank for farming.  Thus, that                  
          interest is personal interest.                                              
               Respondent contends that we should not rely on petitioner's            
          testimony because it is self-serving.  We disagree.  We decide              
          whether a witness is credible based on objective facts, the                 
          reasonableness of the testimony, the consistency of statements              
          made by the witness, and the demeanor of the witness.  Quock Ting           
          v. United States, 140 U.S. 417, 420-421 (1891); Wood v.                     
          Commissioner, 338 F.2d 602, 605 (9th Cir. 1964), affg. 41 T.C.              
          593 (1964); Pinder v. United States, 330 F.2d 119, 124-125 (5th             
          Cir. 1964); Concord Consumers Hous. Coop. v. Commissioner, 89               





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