-19- Unreported Interest Income The next issue is whether petitioners had $40,188 of unreported interest income in 1986. Petitioners presented no credible evidence to rebut the presumption of correctness afforded the notice of deficiency. (We were not impressed with the credibility of petitioner's testimony.) Accordingly, we sustain respondent's determination that petitioners are liable for unreported interest income of $40,188 in 1986. Interest Deduction The third issue is whether petitioners' deduction of $122,605 in 1986 for interest paid to EPIC should be disallowed. Interest is not deductible "if the underlying transaction is a sham * * *. Nor is interest deductible if it is incurred in a transaction 'that can not with reason be said to have purpose, substance, or utility apart from their anticipated tax consequences.'" Sheldon v. Commissioner, 94 T.C. 738, 760 (1990) (citations omitted). In view of our finding that the sale of the BTG stock to EPIC was a sham transaction, the interest payments to EPIC are not deductible. Negligence The final issue is whether petitioners are liable for additions to tax under sections 6653(a)(2) and 6653(a)(1)(B) on the portion of the underpayment attributable to the transfer of the Escondido property to Balmac. Petitioners have conceded the application of all additions to tax raised in respondent's noticePage: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
Last modified: May 25, 2011