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produce evidence that the amounts allowed as either Schedule A or
Schedule C deductions were insufficient or that respondent’s
division of those deductions between Schedules A and C was
improper.4
D. Conclusion
Petitioner has failed to introduce credible evidence (and,
therefore, failed to carry his burden of proving) that he is
entitled to deductions for the years at issue greater than those
allowed by respondent.
III. Respondent’s Computational Errors
A. 1997
The parties have stipulated that one of the disallowed
Schedule C deductions that is allowed as a Schedule A deduction
is $19,119 of mortgage interest. Respondent’s allowance of that
amount as a Schedule A deduction is also reflected in the
examining agent’s Form 886-A, Explanation of Items, for 1997 (the
1997 Explanation of Items). The computation of 1997 Schedule A
deductions contained in the notice, under the heading “per exam”,
allows no interest expense deduction. As a result, the total
allowable itemized deductions for 1997 (before reduction for the
overall limitation on itemized deductions under section 68) is
4 For 1999 and 2000, it is immaterial whether deductions
are allowed on Schedules A or C because petitioner’s Schedule A
deductions for those years are not subject to reduction pursuant
to either sec. 67 (2-percent floor on miscellaneous itemized
deductions) or sec. 68 (overall limitation on itemized
deductions), nor do they generate alternative minimum tax.
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