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As previously stated, at trial, petitioner testified that
the qualified residence was in Ms. Lewis’s name because of his
bad credit history. Petitioner presented no documentary evidence
such as the mortgage itself or canceled checks to prove that the
mortgage was his obligation or that he paid the mortgage interest
during taxable year 2000. Further, Ms. Lewis claimed a deduction
for the home mortgage interest paid on the subject property for
taxable year 2002 in the amount of $6,548. Since petitioner has
failed to provide any proof that the mortgage was his obligation
or that he made mortgage interest payments, we sustain
respondent’s disallowance of petitioner’s claimed deduction of
home mortgage interest.
B. Gifts to Charity
On petitioner’s Schedule A filed with his Federal income tax
return for taxable year 2000, he reported the following gifts to
charity:
Itemized Deductions Amount
Gifts by cash or check $3,300
Gifts other than by cash or check 250
Total gifts $3,550
Respondent determined that petitioner did not adequately
substantiate that “gifts other than by cash or check” were made.
Respondent further determined that, if such gifts were made,
petitioner did not adequately substantiate the fair market value
of the gifts. Accordingly, respondent allowed a deduction for
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