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With respect to the third issue, petitioner claimed itemized
deductions of $6,766 and $8,100 for home mortgage interest under
section 163 for the years 2000 and 2001, respectively. Section
163(h) allows a deduction for interest paid on a qualified
residence. Sec. 163(h)(2)(D). “Qualified residence” within the
meaning of section 163 may be either the taxpayer’s principal
residence or another residence selected by the taxpayer and used
as a residence. Sec. 163(h)(4)(A)(i). Although the petitioner
listed the name of the company to which he paid interest for the
home mortgage interest on his returns, he presented no
substantiation or proof of his interest payments at trial, nor
did he produce either a deed to any property or even a canceled
check to or receipt from any bank or mortgage company.
Therefore, respondent is sustained on this issue and the
deductions are disallowed for 2000 and 2001.
With respect to the fourth issue, petitioner claimed $10,307
and $16,680 as itemized deductions for charitable contributions
for the years 2000 and 2001, respectively. Each deduction was
disallowed in its entirety in the notice of deficiency. A
taxpayer may deduct any charitable contribution made within the
taxable year. Sec. 170(a)(1). The deduction, however, is
subject to verification pursuant to applicable regulations.
Where a taxpayer donates an amount in excess of $250, it is
necessary to substantiate the amount contributed with a
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