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that we have found Mr. Gaffner and Ms. Gaffner paid during that
year, $50,000 of which they wired to J.D.I. Realty and $15 of
which they paid to First Interstate Bank as a wire-transfer fee.
On the instant record, we find that petitioners have failed to
establish the purposes for which the respective payments were
made to Continental Mortgage Company and to J.D.I. Realty.5 On
the record before us, we find that petitioners have failed to
carry their burden of showing that the respective amounts of
$10,000, $50,000, and $15 paid during 1996 to Continental Mort-
gage Company, J.D.I. Realty, and First Interstate Bank are
deductible for that year under section 162(a), section 212, or
any other section of the Code.
We turn now to the respective amounts of $59,130.12,
$64,014.86, $105,679.24, $123,232.28, and $34,707.91 that peti-
tioners contend are interest payments that they made to Commer-
cial Bank during 1992, 1993, 1994, 1995, and 1996.6 On the
instant record, we find that petitioners have failed to carry
their burden of establishing (1) that during each of the years at
5The purpose of the $50,000 payment during 1996 that Mr.
Gaffner and Ms. Gaffner made, via a bank wire of their funds, to
J.D.I. Realty governs the deductibility of the $15 fee that they
paid to First Interstate Bank for that wire transfer.
6At trial, respondent conceded that petitioners are entitled
for 1996 to interest deductions of $36,547.14 and $77,747.58 with
respect to mortgage interest that they paid during that year to
Lornty Investment Co. and SFG Data Mortgage Servicing, Inc.,
respectively.
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