Mahendra K. Tandon - Page 19

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                    Date                     Amount of Interest                       
                    1/11/85                       $449.90                             
                    12/12/85                      362.65                              
                    12/8/86                       310.19                              
                    11/21/87                      294.77                              
                    12/8/87                       291.65                              
                    1/15/88                       291.21                              
                    3/2/88                        299.27                              
          Petitioner also submitted checks for payments to Ohio Savings on            
          or about some of those dates.  Based on the evidence, we conclude           
          that petitioner has failed to substantiate business or mortgage             
          interest deductions in amounts greater than those allowed by                
          respondent; therefore, we sustain respondent's determination on             
          these issues.                                                               
               D.   General Sales Tax on Motor Vehicles                               
               On his 1986 tax return, petitioner claimed a Schedule A                
          general sales tax on motor vehicles deduction of $6,597.10.                 
          Respondent disallowed these deductions.  Respondent argues that             
          petitioner has failed to substantiate the deduction; petitioner             
          claims that he has substantiated his claimed deductions.                    
               In 1986, section 164(a)(4) allowed a deduction for State and           
          local general sales taxes.  Petitioner submitted a lease                    
          agreement executed between himself and Crestmont Cadillac Corp.             
          on December 30, 1986, for the Rolls Royce.  Under the lease,                
          petitioner's monthly payment was $1,219.86, of which $63.59 was             
          separately stated as sales tax.  Petitioner submitted a check               
          dated December 26, 1986, for $1,219.86 payable to Crestmont                 





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