- 8 -
contend are interest payments:
Alleged
Year Interest Payment
1992 $59,130.12
1993 64,014.86
1994 105,679.24
1995 123,232.28
1996 34,707.91
Petitioners also contend that they are entitled to deduct for
1996 (1) $36,910.09 that Ms. Gaffner paid to certain attorneys,
(2) $10,000 that Mr. Gaffner paid to Continental Mortgage Com-
pany, and (3) $50,015, $50,000 of which they paid, via a bank
wire of their funds, to J.D.I. Realty, and $15 of which they paid
to First Interstate Bank as a fee for that wire transfer. On the
record before us, we reject petitioners’ contentions.
We turn first to the amounts totaling $36,910.09 that we
have found Ms. Gaffner paid during 1996 to certain attorneys. On
the instant record, we find that petitioners have failed to
establish the nature of the services performed and/or the nature
of the expenditures incurred by those attorneys. On the record
before us, we find that petitioners have failed to carry their
burden of showing that the amounts totaling $36,910.09 that Ms.
Gaffner paid to various attorneys during 1996 constitute expenses
deductible for that year under section 162(a), section 212, or
any other section of the Code.
We turn next to the $10,000 that we have found Mr. Gaffner
paid during 1996 to Continental Mortgage Company and the $50,015
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011