Roman G. Satko - Page 7

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          $13.12 in 1986.  Petitioner did not make any other interest                 
          payments until July of 2000 when unpaid interest of $4,904.69 was           
          paid.  Petitioner's inability to document any interest he paid on           
          the loans against his life insurance policy up to or during tax             
          year 1999 precludes a deduction for investment interest for 1999.           
          Furthermore, an interest deduction here would provide no benefit            
          for petitioner because it is less than the standard deduction               
          amount.  Greenspun v. Commissioner, 72 T.C. 931, 949 n.20 (1979),           
          affd. 670 F.2d 123 (9th Cir. 1982).                                         
               Petitioner has not presented any evidence which would                  
          demonstrate that the interest he received in the settlement is              
          not income to him.  Thus, respondent's determination is                     
          sustained.                                                                  
          Reviewed and adopted as the report of the Small Tax Case                    
          Division.                                                                   
               To reflect the foregoing,                                              
                                                  Decision will be entered            
                                             for respondent.                          
















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