Ronna Joan Robertson - Page 10




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          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.                   






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