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Upon the basis of the record in this case and giving
petitioners the benefit of the doubt, we conclude that they have
substantiated real estate taxes paid in the amount of $1,930.60
with respect to their Chicago, Illinois, property. This amount
is in addition to the portion of $1,017 of the Schedule A
deduction for real estate taxes allowed by respondent with
respect to petitioners’ Florida properties.
3. Home Mortgage Interest
On their Schedule A for taxable year 1999, petitioners
claimed a deduction of $4,937 for home mortgage interest paid
during taxable year 1999. Respondent agrees that petitioners are
entitled to deduct, under section 163, $4,796 of the claimed
deduction for home mortgage interest. However, respondent
contends that petitioners are not entitled to the additional
$141. Respondent determined that petitioners did not prove that
they paid home mortgage interest in excess of $4,796 during
taxable year 1999.
Section 163(a) allows a deduction for all interest paid or
accrued within the taxable year on indebtedness. Section
163(h)(1), however, provides that, in the case of a taxpayer
other than a corporation, no deduction is allowed for personal
interest. Qualified residence interest is excluded from the
definition of personal interest and thus is deductible under
section 163(a). See sec. 163(h)(2)(D). Qualified residence
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