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The amount petitioner borrowed against his insurance policy
was not secured by his house. We conclude that any interest paid
on this loan is not deductible. Sec. 163(h).
Accordingly, we sustain respondent’s determination to
disallow $6,862 of petitioner’s home mortgage interest deduction
for 2000.
3. Miscellaneous Deductions and Schedule C Items
Petitioner presented no evidence regarding his “job expenses
and most other miscellaneous deductions” for 1999, his “other
miscellaneous deductions” for 2000, and his Schedule C expenses
and cost of goods sold for 1999 and 2000. Accordingly, we
sustain respondent’s determinations regarding these amounts. See
Rule 142(a); Welch v. Helvering, 290 U.S. at 115.
III. Self-Employment Tax
At trial, petitioner briefly disputed respondent’s
determination of self-employment tax. Respondent determined, on
the basis of the disallowed Schedule C deductions and cost of
goods sold, that petitioner had additional self-employment income
during 1999 and 2000.
Section 1401 imposes self-employment tax on self-employment
income. Section 1402 defines net earnings from self-employment
as the gross income derived by an individual from the carrying on
of any trade or business by such individual less allowable
deductions attributable to such trade or business.
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