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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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Last modified: May 25, 2011