- 148 - category. Petitioner failed to carry his burden of proving that respondent erred in determining that the remaining $12,759.63 constitutes unreported constructive dividend income to Betsy. In supra table 12, we set forth our conclusions that $8,173.56 of the disputed 1986 amounts were constructive dividends to Betsy, that $160.22 were Sley Corporations’ business expenses, and that we could not find that the remaining $3,325.84 of disputed Markette payments fit into either category. Petitioner failed to carry his burden of proving that respondent erred in determining that the remaining $3,325.84 constitutes unreported constructive dividend income to Betsy. We hold for respondent on this issue, except that we hold for petitioner as to $90 for 1985 and as to $160.22 for 1986. B. Interest Deduction Respondent contends that petitioner’s and Betsy’s 1987 joint tax return overstated an itemized personal interest deduction by $8,559. Petitioner contends that the interest deduction was properly taken for 1987. The deduction in issue stems from the $13,167.96 interest payment Betsy made to Markette. We agree with respondent’s conclusion.Page: Previous 137 138 139 140 141 142 143 144 145 146 147 148 149 150 151 152 153 154 155 156 Next
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