- 8 -
v. Skelly Oil Co., supra at 684). The Court sustains
respondent's determinations disallowing petitioner's advertising
expense deductions and the improperly claimed amounts for costs
of goods sold.
2. Mortgage Interest
For 1998 and 1999, petitioner claimed deductions for
mortgage interest on her Schedules C. Petitioner alleges she
paid a mortgage in her father's name largely because Mr. Blake
assumed in full and refinanced petitioner's 1984 business loan
which he had originally cosigned. Petitioner has not provided
evidence to show what portion of the mortgage payments, if any,
represents interest on the debt she owed her father. Therefore,
she is not entitled to Schedule C business interest deductions.
Section 163(a) allows a deduction for interest paid or
accrued within the taxable year on indebtedness. The
"indebtedness" for purposes of section 163 must, in general, be
an obligation of the taxpayer and not an obligation of another.
Golder v. Commissioner, 604 F.2d 34, 35 (9th Cir. 1979), affg.
T.C. Memo. 1976-150; Smith v. Commissioner, 84 T.C. 889, 897
(1985), affd. without published opinion 805 F.2d 1073 (D.C. Cir.
1986); Hynes v. Commissioner, 74 T.C. 1266, 1287 (1980).
However, section 1.163-1(b), Income Tax Regs., provides, in
pertinent part:
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