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Section 166 allows a taxpayer to deduct any business debt
which becomes wholly or partially worthless during the taxable
year. Sec. 166(a), (d)(1)(A). Section 166 also allows a tax-
payer who guaranties a debt and makes a payment pursuant to that
guaranty to deduct that payment, provided that the taxpayer
satisfies the requirements of section 1.166-9, Income Tax Regs.
Claimed Interest Deductions
Petitioner contends that he is entitled to deduct for 1991
and 1992 interest payments that he made on petitioner’s equity
line account during those years in the amounts of $1,632.18 and
$1,176.48, respectively. Petitioner also contends that he is
entitled to deduct for 1992 interest of $1,250 that he claims he
paid on an alleged business loan from Mr. Kroma.
With respect to the interest payments on petitioner’s equity
line account that are at issue, we have found that petitioner
paid interest in the respective amounts of $1,632.18 and
$1,176.48 on that account during 1991 and 1992. Prior to the
filing of petitioner’s opening brief, petitioner took the posi-
tion that he is entitled to deduct 50 percent of those interest
payments because he “incurred these expenses in conducting his
business”. On brief, petitioner contends that he is entitled to
deduct all of the interest payments that he made during 1991 and
1992 on petitioner’s equity line account because that account
“was used primarily for business and the production of income.”
We infer, and we conclude, from petitioner’s argument that he
used petitioner’s equity line account “primarily” for business
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