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Discussion
Petitioner contends that she should be allowed a mortgage
interest deduction relating to payments she allegedly made to
Westco Investments. She does not dispute respondent’s
disallowance of deductions relating to payments made to other
banks. In addition, petitioner contends that she is entitled to
the charitable contribution deductions because she paid all
expenses on behalf of All Creatures, an organization she contends
is a tax-exempt charitable organization pursuant to section
501(c)(3). Respondent contends that petitioner has not
substantiated her mortgage interest and charitable contribution
deductions.
Pursuant to section 163(h)(3), a taxpayer is entitled to
deduct qualified residence interest but must maintain sufficient
records to substantiate the amounts of the deduction. See sec.
6001; sec. 1.6001-1(a), Income Tax Regs. Petitioner has failed
to do so. In addition, petitioner has failed to substantiate her
charitable contribution deductions. Accordingly, we sustain
respondent’s determinations.2
2 Sec. 7491(a) is inapplicable because petitioner failed to
introduce credible evidence within the meaning of sec.
7491(a)(1).
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Last modified: November 10, 2007