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petitioner spent on gasoline. We conclude that petitioner has
failed to substantiate his car and truck expenses for 1985 and
1986.
C. Business and Mortgage Interest
Petitioner claimed Schedules C business interest deductions
in the amounts of $2,723.27, $3,097.03, and $2,767.96 in 1985,
1986, and 1987, respectively, and Schedules A mortgage interest
deductions in the amounts of $4,380.20, $6,053.76, $5,066.02, and
$4,949.78 in 1985, 1986, 1987, and 1988, respectively.
Respondent allowed petitioner business interest deductions in the
amounts of $1,861.27, $2,749.03, and $2,419.96 in 1985, 1986, and
1987, respectively, and mortgage interest deductions in the
amounts of $4,287.20, $4,286.76, $4,663.02, and $3,804.78 in
1985, 1986, 1987, and 1988, respectively. Respondent argues that
petitioner has failed to substantiate deductions in amounts
greater than those allowed; petitioner claims that he has
substantiated his claimed deductions.
Section 163(a) allows a deduction for all interest paid or
accrued within the taxable year on indebtedness. Petitioner
submitted customer records of a loan drawn from the Ohio Savings
Association. There is no evidence of what kind of loan this was;
i.e., whether it related to business or nonbusiness interest.
The records petitioner submitted showed the following amounts of
interest paid by petitioner:
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