- 15 - 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 inPage: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Next
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