Jerry S. Payne - Page 39

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          Deductions Still in Dispute and Additional                                  
          Deductions Claimed by Petitioner                                            
               As indicated above (see supra p. 21), petitioner still disputes        
          respondent’s disallowance of $167,035 and $76,963 in business and           
          itemized deductions claimed on petitioner's respective 1987 and 1988        
          Federal income tax returns.  Petitioner also seeks to claim herein          
          additional business and itemized deductions of $110,835 and $185,219        
          for 1987 and 1988 (see supra p. 22), respectively.  Based on our            
          findings of fact, our conclusions as to the above claimed deductions        
          are set forth below.                                                        

                  Claimed Business Interest Deductions -- 1987 and 1988               
               Petitioner argues that the entire $117,074 for 1987 and $37,024        
          for 1988 in claimed business interest (see supra p. 21) is deductible       
          as such.  For 1987, the $117,074 claimed business interest consists         
          of $76,361 paid on petitioner’s guaranty to TexCommBk and $40,713           
          paid to other banks.  For 1988, the $37,024 in disputed business            
          interest consists of $19,139 paid on petitioner's guaranty to               
          TexCommBk and $17,885 paid to other banks.  Alternatively, with             
          respect to the $76,361 for 1987 and the $19,139 for 1988 that were          
          paid to TexCommBk, petitioner argues that he is entitled to a               
          business bad debt deduction.                                                
               The evidence is incomplete and confusing with regard to many of        
          the payments petitioner made to various banks.  In attempting to            
          substantiate the claimed business interest deduction, petitioner            
          merely identified checks to various banks that in total approximated        




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