- 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.
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