Lorianne Blake - Page 9

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          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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