Zinovy Brodsky - Page 40




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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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