- 39 - 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 approximatedPage: Previous 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 Next
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