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loss carried over into the years in issue, surviving petitioners’
own personal bankruptcy. The documents that petitioners have
submitted to the Court as evidence of their entitlement to
carryovers are haphazard at best, and no apparent attempt was
made to calculate for the Court the actual amount of the capital
loss carryovers, other than to state that the losses offset the
gains in full in the years in issue. Finally, petitioners’
argument with respect to this issue is suspect because
petitioners failed to report any of the alleged capital losses on
their returns in the years in issue.
We hold that petitioners have not substantiated the
existence of a capital loss carryover that would offset the
capital gain income determined by respondent in any of the years
in issue. Sec. 6001; sec. 1.6001-1(a), (e), Income Tax Regs.
Mortgage Interest Expense
Petitioners claimed an itemized deduction for mortgage
interest expense of $8,732 in 1996. Respondent decreased this
deduction, allowing a deduction of only $3,732.
Mortgage interest expense generally is deductible by
individual taxpayers, subject to various limitations not relevant
here. Sec. 163(a), (h).
Petitioners have not substantiated that they paid mortgage
interest expense of any amount in 1996. We therefore sustain
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