John A. Rowe and Donna L. Rowe - Page 30




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          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 was                                        








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