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Petitioner is entitled to deduct tax payments in each of the
years at issue in the amounts conceded by respondent and allowed
under the Cohan rule. The amounts are shown on the chart at page
79 of this opinion.
p. Interest
For the years at issue, petitioner claimed deductions for
interest paid in connection with her law practice as follows:
Year Amount
1987 $10,034
1988 3,053
1989 2,926
1990 2,070
Mr. Aunan’s workpapers include a workpaper labeled “Business
Interest”, which contains the following entries:
1987 1988 1989 1990
Citibank MasterCard $260.00 $319.50 $365.45 $258.66
Amex Gold
Citibank Visa -- 202.07 270.63 235.71
Citibank Preferred -- -- 232.16 581.82
First Card 365.93 790.58 910.97 870.01
Amex Green 1.47 17.04 81.37
TCF Visa -- -- 284.59 --
625.93 1,313.62 2,080.84 2,027.57
The total amount of credit card interest in each year was then
rounded and added to amounts characterized as “Capital Loan” to
arrive at the total business interest deducted in each of the
years at issue:
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