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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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