- 10 - license was required under California law. In short, petitioner has failed to substantiate her claim for a deduction, and accordingly, no deduction is allowed for her automobile sales license. E. Interest Expense Section 163(a) provides a deduction for interest paid or incurred on indebtedness within the taxable year. Not all interest incurred, however, is deductible. In October 1989, petitioner borrowed $12,070.46 to purchase a 1986 Pontiac Grand Prix at a 12.5-percent interest rate. In 1993 and 1994, petitioner paid $481.65 and $118.19, respectively, of interest on this loan. Petitioner also paid $8,189.68 and $7,386.58 of mortgage interest during the 1993 and 1994 taxable years, respectively. Section 163(h) denies taxpayers a deduction for personal interest paid or accrued during the taxable year unless it fits within certain narrowly prescribed categories. The interest paid by petitioner on her personal car loan during 1993 and 1994 is personal in nature and does not fall into one of the excepted categories. Accordingly, petitioner is not entitled to deduct the interest paid on her personal car loan. Section 163(h)(2)(D), however, allows a deduction for interest on a qualified residence. Respondent concedes that petitioner is entitled to deductions for the interest paid on the mortgage for petitioner’s home during the 1993 and 1994 taxable years.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011