William Joel Ashley - Page 11




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          he incurred and paid in 1994.  The parties have stipulated that             
          these expenditures amount to $13,215.94.6                                   
               Finally, we address petitioner’s claim that $4,782.15 in               
          refinancing costs must be included in the adjusted basis of the             
          Longport property.  While we agree that expenses incurred in                
          connection with securing a loan must be capitalized, we have                
          previously stated that those expenses must be amortized and                 
          deducted over the life of the loan.  See The Austin Co. v.                  
          Commissioner, 71 T.C. 955, 965 (1979); Buddy Schoellkopf Prods.,            
          Inc. v. Commissioner, 65 T.C. 640, 649 (1975).  If the loan is              
          repaid prior to maturity, however, “the unamortized expenses may            
          be fully deducted in the year of repayment.”  Buddy Schoellkopf             
          Prods., Inc. v. Commissioner, supra at 649; see Anover Realty               
          Corp. v. Commissioner, 33 T.C. 671, 674 (1960).  We estimate the            
          unamortized costs at $3,800, which petitioner is entitled to                
          deduct.  See Cohan v. Commissioner, 39 F.2d 540, 543-544 (2d Cir.           
          1930), affg. in part and remanding in part 11 B.T.A. 743 (1928).            
          II. Schedule A, Itemized Deductions                                         
               In documents submitted to the Court, petitioner claims (1) a           
          $70,078.01 deduction for casualty losses to his real and personal           
          property, (2) a $3,244.08 and a $26,691.43 deduction for taxes              
          and interest, respectively, with regard to two homes, and (3) a             


               6  We note that petitioner is also entitled to a deduction             
          for depreciation relating to 1994.  The benefit that petitioner             
          receives from the depreciation deduction for 1994, however, is              
          offset by a lower adjusted basis in the Longport property and the           
          personal property.                                                          





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