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Clare Golnick, for petitioners.
Paul L. Dixon, for respondent.
OPINION
TANNENWALD, Judge: Respondent determined deficiencies in
petitioners' 1989 and 1990 Federal income taxes in the amounts of
$46,409 and $6,927, respectively. The issue in dispute is
whether petitioners may deduct certain interest on Federal income
tax deficiencies, paid by petitioners in 1989 and 1990, where the
deficiencies arose in part due to a correction for errors made in
computing petitioners' income from their business.
All the facts have been stipulated. The stipulation of
facts and attached exhibits are incorporated herein by this
reference.
Background
At the time the petition was filed, petitioner James E.
Redlark was a resident of Palm Springs, California, and
petitioner Cheryl L. Redlark was a resident of South Lake Tahoe,
California.
Respondent examined petitioners' Federal income tax returns
for 1979, 1980, 1981, 1982, 1983, 1984, and 1985, following which
respondent and petitioners agreed to adjustments to petitioners'
income for each of the years.
The adjustments were due in part to a correction for errors
made in converting petitioners' revenue from Carrier
Communications, petitioners' unincorporated business, from an
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