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reconstruction of those expenses. Petitioner’s only argument
relates to certain deductions he claims for alleged expenses from
his orange grove, cattle, and Ferrari automobile collection
activities. We hold that petitioner has conceded any arguments
relating to respondent’s reconstruction of the allowable expenses
for his real estate business.
2. Personal Residence Interest
FINDINGS OF FACT
On August 31, 1981, petitioner purchased his personal
residence in Osceola County, Kissimmee, Florida, from Walter E.
and Maxine J. Melitshka.66 Petitioner borrowed certain amounts
from the Melitshkas for the purchase of this residence. The
amount of the loan, the interest rate, the repayment terms for
the loan, and the actual amount of interest petitioner paid
during tax years 1985, 1986, 1987, and 1988 were not established
on the record.
OPINION
Respondent determined that petitioner was entitled to
deductions for mortgage interest paid on his personal residence
of $24,957, $0, $41,759, and $16,249 for 1985, 1986, 1987, and
1988, respectively. Petitioner does not challenge those
determinations on brief, and, accordingly, he has conceded the
66The residence was originally titled in the name of Mr.
Miles, as trustee; however, on Aug. 10, 1990, Mr. Miles conveyed
title to the residence to petitioner.
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