- 127 - we are not required to, and we shall not, rely. We have found that petitioner has failed to carry his burden of establishing (1) that Mr. Kroma made a $50,000 loan to UVW, (2) that Mr. Kroma received the proceeds of petitioner’s July 13, 1992 check, and (3) that, even if Mr. Kroma had received the proceeds of that check, those proceeds represented 2 months’ interest on the alleged $50,000 loan from Mr. Kroma to UVW. On the record before us, we find that petitioner has failed to carry his burden of establishing that he is entitled under section 163 to deduct (1) for 1991 and 1992 interest payments of $1,632.18 and $1,176.48, respectively, that he made during those years on petitioner’s equity line account and (2) for 1992 the claimed interest payment of $1,250. Claimed Telephone Expense Deductions Petitioner contends that he is entitled to deduct for 1991 and 1992 certain telephone expenses that he paid during those years. During 1991 and 1992, petitioner maintained (1) separate home telephone lines, one of which was supposed to be used for personal purposes and one of which was supposed to be used for business purposes, and (2) separate cellular telephone lines, one of which was supposed to be used for personal purposes and one of which was supposed to be used for business purposes. With respect to petitioner’s home telephone lines, petitioner claims that he is entitled to deduct for 1991 and 1992 telephone ex- penses of $1,393.24 and $1,059.27 that he paid during those respective years, which he contends are the amounts of telephonePage: Previous 117 118 119 120 121 122 123 124 125 126 127 128 129 130 131 132 133 134 135 136 Next
Last modified: May 25, 2011