N. Joseph Calarco - Page 21

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          2.   Automobile Depreciation                                                
               Having decided that petitioner failed to substantiate his              
          mileage, we are compelled to disallow petitioner’s claimed                  
          depreciation deduction as well--to claim any deduction related to           
          use of his personal automobile, petitioner must meet the enhanced           
          substantiation requirements.  Whalley v. Commissioner, T.C. Memo.           
          1996-533.                                                                   
          3.   Interest                                                               
               Petitioner claimed $7,392 in interest expenses.  To the                
          extent that this amount reflects otherwise deductible mortgage              
          interest, respondent allowed its deduction in the notice of                 
          deficiency, and we sustain that allowance.                                  
               Petitioner also submitted documentation of $4,880 in                   
          interest expenses from his various credit cards.  In Exhibit 17-            
          P, petitioner showed that the proper percentage of credit card              
          interest allocable to his Schedule C expenses is 78 percent.  We            
          believe this amount is overly generous to petitioner, especially            
          in light of the excess claims we find he made in the supply                 
          category.  See infra.  Still, petitioner has shown that he paid             
          substantial interest charges on many consumer credit cards for              
          expenses properly attributable to his Schedule C activities.                
          Under the Cohan rule, when presented with some factual basis upon           
          which to rely, we are allowed to estimate the amount of interest            
          deductions properly allowable.  Schroeder v. Commissioner, T.C.             
          Memo. 1996-336.  We estimate that 65 percent of the claimed                 




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