- 40 -
therefore entitled to deduct only that portion of the points
allocable to 1999 as a portion of the 30-year loan. Cf. Square D
Co. & Subs. v. Commissioner, 121 T.C. 168, 194 nn.21 & 22 (2003).
From the record before us, that amounts to $250.
C. SEP-IRA Contributions
At trial, Dr. Rinker testified that she made contributions
to three different SEP-IRA funds in 1999, and petitioners argued
that they should be allowed a deduction for the 1999
contributions. Petitioners did not claim a deduction for the
contributions on their 1999 return because, on the basis of the
Schedule C income shown on the return, no deduction was
permissible. However, petitioners argued that, on the basis of
respondent’s adjustments and petitioners’ concessions with regard
to the Schedule C income, such a deduction would now be allowable
and appropriate.
Even if the Court accepts Dr. Rinker’s uncorroborated
assertions that she contributed money to retirement accounts,
petitioners have failed to provide the Court with any evidence
that Dr. Rinker made the contributions under plans that meet the
qualifications for SEP-IRA’s. See secs. 219, 401, 408. We
therefore conclude that petitioners are not entitled to a
deduction for the contributions in 1999.
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