- 126 - and the production of income that petitioner concedes that he used that account at least partially for personal purposes. In support of his contention that he used petitioner’s equity line account primarily for business and the production of income, petitioner relies on his self-serving testimony, on which we are not required to, and we shall not, rely. Assuming arguendo that petitioner had established that he used peti- tioner’s equity line account primarily for business and the production of income, on the instant record, we find that peti- tioner has failed to carry his burden of showing that he is entitled to deduct the respective amounts of interest payments on petitioner’s equity line account that he made during 1991 and 1992. In this connection, we find on that record that petitioner has failed to establish the portion, if any, of petitioner’s equity line account that he used during 1991 and 1992 for busi- ness and/or income-producing activities and to allocate the interest payments at issue for purposes of applying sections 163(d) and (h) and 469. See sec. 1.163-8T, Temporary Income Tax Regs., 52 Fed. Reg. 24999 (July 2, 1987). With respect to the $1,250 of alleged interest that remains at issue, petitioner contends that his $1,250 check dated July 13, 1992, which was payable to Mr. Kroma, drawn on petitioner’s equity line account, and signed by petitioner (petitioner’s July 13, 1992 check), represented a payment of 2 months’ interest on a $50,000 loan from Mr. Kroma to UVW. In support of that conten- tion, petitioner relies on his self-serving testimony, on whichPage: Previous 116 117 118 119 120 121 122 123 124 125 126 127 128 129 130 131 132 133 134 135 Next
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