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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 telephone
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