Peter Milton Joseph and Ella Joseph, Deceased - Page 15

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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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