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business or deductible as an ordinary and necessary business
expense. See id. at 602.
Conclusion
Petitioners have failed to carry their burden of proving
that the interest expense deduction they took for interest paid
to the Service on their tax deficiencies was allocable to a trade
or business within the meaning of section 163(h)(2)(A). To
reflect the foregoing and concessions by the parties,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011