- 30 - barn, a maintenance shed, and a larger building. A sign on the road indicated that the lot was the Lake Gentry Horse Farm. On the adjoining lot, petitioners constructed a new residence. From May 1987 until late 1988, petitioners temporarily resided at property known as Acorn Court while their new home was being constructed. In the summer of 1988, petitioners moved into their new residence. The total cost for the Albritton property and the new residence exceeded $1 million. The residence was jointly titled in the names of petitioner and Mr. Rowe. On the Schedule A, Itemized Deductions, attached to their 1987 return, petitioners claimed a home mortgage interest deduction of $62,545. Petitioners substantiated $50,376 of this amount. Respondent disallowed the remaining $12,169 of the claimed deduction on the basis of a lack of substantiation. On the Schedule A attached to their 1988 return, petitioners claimed a home mortgage interest deduction of $97,341. On the attached Schedule A, the notation “84,186 + 13,155" appears next to the figure $97,341. The Schedule E, Supplemental Income Schedule, attached to the return lists $13,155 as mortgage interest paid on rental property identified as “Bayview House”. Petitioners substantiated $84,186 of the amount claimed for the home mortgage interest deduction. The remaining $13,155 of the home mortgage interest deduction wasPage: Previous 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 Next
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