Douglas R. and Jane E. Prince - Page 13

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          proceeds of the sale of the Yorkville building.  Petitioners                
          argue that they have substantiated their interest expense.                  
               To substantiate their interest payment on the Yorkville loan           
          petitioners rely on petitioner's testimony and an interest                  
          statement.  At trial, petitioner testified that, at the closing             
          of the sale on the Yorkville building, the interest on the loan,            
          which was in arrears, was paid from the proceeds from the sale.             
          Additionally, the record contains a copy of a statement from                
          First Midwest Bank/Illinois that states, in part:  "the interest            
          paid on your loan account in 1988 was $74,722.55."  Respondent              
          concedes that the loan account related to the Yorkville loan.               
          Based on the foregoing, we are satisfied that the interest on the           
          Yorkville loan was paid.                                                    
               Respondent's contention that petitioners did not prove that            
          the proceeds from the sale of the Yorkville building were used to           
          make the interest payment is misplaced.  Where there is no                  
          allegation that the funds to pay the interest were borrowed from            
          the creditor, there is no requirement that the source of the                
          funds used to make the interest payment be traced.  Respondent              
          has not cited, and we are unable to find, any authority to the              
          contrary.  Consequently, the failure of petitioners to establish            
          that the sale of the Yorkville building produced sufficient                 
          proceeds to pay off the Yorkville loan is immaterial.  The only             
          fact petitioners must establish is that the interest on the                 
          Yorkville loan was paid, and that fact is shown by petitioner's             




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