- 4 - calculated under the economic accrual method, respondent treated the portion of each monthly payment that does not represent allowable interest as a repayment of principal. Respondent’s calculation thus reduces or amortizes each month the principal portion of the Partnership’s indebtedness on the promissory note that is to be recognized for Federal income tax purposes. Under such calculation, the allowable interest deduction for each succeeding month is also reduced, and the full $2,370,000 principal portion of the Partnership’s indebtedness that is to be recognized for Federal income tax purposes will be treated as paid off in just over 6 years. Petitioner argues that because the Court in the first of the above Levy opinions, 92 T.C. at 1365, sets forth a schedule of the precise amount of the interest deductions allowable under the economic accrual method (based on the Partnership’s total stated indebtedness on the promissory note of $4,770,000) and because the Court in the second of the above Levy opinions, T.C. Memo. 1991-646, recognized for Federal income tax purposes approximately one-half or $2,370,000 of the $4,770,000 stated principal on the indebtedness, petitioner should now be allowed to treat the same percentage, or one-half, of each monthly $43,725 payment (namely, $21,862) as interest properly accruable under the economic accrual method and to disregard the balance of each monthly payment for purposes of calculating, for subsequentPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011