- 49 -
respective uses during those years of certain Burien Nissan
automobiles.41 On that record, we sustain those determinations.
Petitioners’ Claimed Deductions for
Certain Mortgage Interest and Property Taxes
Respondent determined to disallow any deductions for mort-
gage interest and property taxes claimed by petitioners for each
year at issue in excess of the deductions claimed by them for
each such year for mortgage interest and property taxes paid with
respect to the Sumner property.42
The parties agree that the mortgage interest and property
taxes at issue are attributable to the debt that Mr. Whitehead
and Essie Whitehead incurred when they refinanced the Kirkland
property in February 1994. The parties’ disputes are whether Mr.
Whitehead paid any portion of the disallowed mortgage interest
and property taxes and, if he did pay a portion of the mortgage
interest at issue, whether that interest constitutes qualified
41We note that, when Mr. Stanford was president of Burien
Nissan, his employment agreement provided that he was entitled to
unrestricted access to two Burien Nissan automobiles for his
personal use. Mr. Whitehead could have received the same benefit
when he became president of Burien Nissan.
42Respondent also determined to disallow the deduction for
points not reported in Form 1098 that petitioners claimed with
respect to the Kirkland property for each year at issue. Peti-
tioners make no argument on brief with respect to their entitle-
ment to the deduction that they claimed for each year at issue
for those points. We conclude that petitioners have abandoned
contesting respondent’s determinations disallowing the deductions
claimed for those points. See Rybak v. Commissioner, 91 T.C.
524, 566 n.19 (1988).
Page: Previous 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 NextLast modified: May 25, 2011