Robert W. and Janet L. Carlson - Page 4




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          Sun elected to report the income from the installment sales using           
          the installment method, as permitted under section 453(l)(2)(B).            
               During each year at issue, petitioner, in his capacity as a            
          shareholder, paid an additional tax equal to the interest on the            
          tax deferred as a result of Aqua Sun's election of the                      
          installment method.  The amount of interest was determined with             
          reference to petitioners' tax liability for the previous tax                
          year, so that the interest paid in 1993, 1994, 1995, and 1996               
          related to petitioners' Federal income tax liability on Aqua                
          Sun's installment sales of timeshare units, as reported on                  
          petitioners' returns for 1992, 1993, 1994, and 1995,                        
          respectively.                                                               
               Petitioners computed the interest on the deferred tax                  
          liability in accordance with section 453(l)(3)(B) and reported              
          the interest as a business deduction on Schedule E, Part II, of             
          Forms 1040 for 1993, 1994, 1995, and 1996, in the following                 
          amounts:                                                                    
                    Year                     Interest Paid                            
                    1993                     $382,127                                 
                    1994                     563,169                                  
                    1995                     536,124                                  
                    1996                     501,077                                  
               In the notices of deficiency, respondent disallowed                    
          petitioners' interest deductions in full because petitioners had            
          failed to establish that said interest payments were allowable              
          business interest expense deductions.                                       





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