- 2 - amounts of $3,790 and $2,903, respectively. After concessions, the sole issue for decision is whether petitioners are entitled to an interest deduction for interest they paid to the Internal Revenue Service (the Service) during 1991 on tax deficiencies for earlier years.3 Background This case was submitted fully stipulated pursuant to Rule 122. The stipulation of facts and the attached exhibits are incorporated herein by this reference, and the facts contained therein are found accordingly. At the time the petition was filed, petitioners resided in Thornton, Colorado. During the year in issue, Fred Michael (petitioner) was unemployed. Petitioner Yvonne Michael's principal business was running Four Sisters, an Indian art retail store. 1(...continued) Tax Court Rules of Practice and Procedure, unless otherwise indicated. 2Petitioners concede that they are liable for an addition to tax under sec. 6651(a)(1) equal to 25 percent of any deficiency determined herein. 3On their 1991 joint Federal income tax return, petitioners deducted $21,286.76 on Schedule A as legal fees. Respondent concedes that $7,211 is an allowable deduction for legal fees under sec. 212 but is subject to the 2 percent of adjusted gross income limitation on Schedule A. Petitioners concede that the remaining $14,075.76 claimed as legal fees is not an allowable deduction. Respondent concedes that petitioners are not liable for an accuracy-related penalty under the provisions of sec. 6662(a).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
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