- 11 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
Last modified: May 25, 2011