Zabetti A. Pappas - Page 63




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          that the amount of $400, paid to an attorney in connection with             
          obtaining a lease for the W. 58th Street apartment, is properly             
          deductible, because, as we have found above, she used that                  
          apartment for income-producing purposes.                                    
               Petitioner’s testimony and the introduction of a cancelled             
          check indicates that she paid her brother $150 in 1990 for                  
          appraisal fees concerning some property in Ohio that was                    
          inherited from their father.  Petitioner argues that she, as Real           
          Services, might have been interested in selling the property at a           
          profit and is therefore entitled to deduct this $150.  As was the           
          case with the 1989 Hawaiian property expenditures, however,                 
          petitioner has failed to show that the $150 qualifies as a                  
          deduction.  She testified that, when the property was sold, “Real           
          Services was returned $175 in regard to this loan”.  It thus                
          appears that her check for $150, rather than being a deductible             
          expense, was a loan or advance to her brother.                              
               C.  Interest Deductions in 1990                                        
               Petitioner borrowed money from a number of people in 1990              
          and now claims that she should be allowed to deduct the interest            
          she paid to her lenders.  Petitioner, however, has failed to                
          establish that she actually paid such interest.  As noted above,            
          she borrowed $4,000 from Michael L. and, a few months later,                
          wrote him a check in repayment of $4,800.  But the repayment                
          check was dishonored, and Mr. L. acknowledged that his loan was             






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