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year 1999. However, it is not clear from the record if this
payment of home mortgage interest to EMC has already been
included in the $4,796 allowed by respondent.
Therefore, we find that petitioners have failed to provide
any substantiation to support their claimed payments of home
mortgage interest in excess of the $4,796 allowed by respondent.
We find we cannot estimate any amounts of petitioners’ deductions
under the Cohan rule, and we sustain respondent’s disallowance of
petitioners’ claimed payments of home mortgage interest in excess
of $4,796. Sec. 6001; sec. 1.6001-1(a), (e), Income Tax Regs.
4. Miscellaneous Deductions
On their Schedule A for taxable year 1999, petitioners
claimed miscellaneous deductions of $33,785 for job expenses
incurred during taxable year 1999. The deduction was claimed for
expenses incurred while petitioner attended English Literature
courses at Worcester College in Oxford, England. Respondent
disallowed the aforesaid deduction in full. Respondent
determined that petitioners did not prove that the expenses were
incurred or, if incurred, that they were paid during taxable year
1999, nor did petitioners prove that if the expenses were
incurred and paid, the expenses were ordinary and necessary to
petitioner’s business.
Section 162(a) allows a deduction for ordinary and necessary
business expenses paid or incurred during the taxable year in
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