Steve J. Work - Page 13

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          contributions).  Accordingly, we sustain respondent’s                       
          determination to disallow the costs of petitioner’s lunches at              
          the DMNH as deductions for 1999 and 2000.                                   
               Petitioner also claimed that he made charitable                        
          contributions to the Northern Colorado Woodcarvers Association              
          (NCWA) and the Buffalo Creek Gun Club (BCGC).  Petitioner                   
          presented no evidence of the amounts he gave to NCWA or BCGC.               
          See id.  Additionally, there is no evidence that contributions to           
          NCWA or BCGC qualify as “charitable contributions” under section            
          170(c).  Accordingly, we sustain respondent’s determinations to             
          disallow the remainder of petitioner’s charitable contribution              
          deductions for 1999 and 2000 that respondent did not concede.               
                    2.  Home Mortgage Interest                                        
               Respondent allowed petitioner $4,930 of home mortgage                  
          interest as a deduction for 2000.  At trial, petitioner submitted           
          a settlement statement concerning a house he purchased in 2000 in           
          Monument, Colorado.  The settlement statement listed:  (1)                  
          $370.65 of interest paid from October 17 to November 1, 2000; (2)           
          $611.50 for a loan origination fee; and (3) $2,446 for a broker             
          discount.  Assuming arguendo that the $370.65 in interest equals            
          a daily interest rate of $24.71 ($370.65 divided by 15 days),               
          petitioner paid $24.71 in interest per day on the mortgage from             
          October 17 through December 31, 2000 (76 days), and the “total              
          interest” would be $1,877.96 ($24.71 times 76).  This “total                






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