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petitioner knew or believed that petitioners’ home mortgage
interest was limited to $66,105.
Respondent’s sole contention is that because petitioner had
actual knowledge of the amount of interest payments in 1987 and
1988, petitioner also had actual knowledge of the amount of
interest paid on the mortgage in 1990. Petitioner agrees that
she knew of the mortgages; however, she claims that she was
unaware of the amount of interest paid or that it was incorrectly
reported on the tax returns. Petitioner claims that the interest
payments for 1990 were deducted on Schedule A as home mortgage
interest and on Schedule F as farm interest expense. Petitioner
contends that she did not know how much interest was paid on the
mortgage, and, because she was allowed to review the first two
pages only of the 1990 return and not the corresponding
schedules, she was unaware that the interest payments were
deducted twice.
No evidence was presented establishing what funds were used
to make the mortgage interest payments in 1990. Our review of
the bank statements for 1990 for the NCNB account reveals that
the opening balance was approximately $1,855 and that deposits
totaling only approximately $7,086 were made during that year.
Thus, it appears that little, if any, funds were used from the
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