- 2 - Federal income tax in the amount of $9,687. Following concessions, the issues for decision are: (1) Whether petitioners are entitled to an interest expense deduction claimed as a miscellaneous itemized deduction on their 1991 Federal income tax return (the 1991 return); (2) whether petitioners are entitled to an additional interest deduction not claimed on their 1991 return; (3) whether petitioners are entitled to various employee business expense deductions claimed for the year 1991; and (4) whether petitioners are entitled to a deduction for credit life insurance premiums paid in 1991. FINDINGS OF FACT Some of the facts have been stipulated and are so found. Petitioners filed a joint Federal income tax return for the year 1991. They computed their 1991 Federal income tax liability in accordance with the cash receipts and disbursements method of accounting. At the time the petition was filed, petitioners resided in Tulsa, Oklahoma. References to petitioner are to Samuel C. Stone. Petitioner is, and was during the year in issue, a practicing attorney specializing in the issuance of municipal securities. Petitioner conducted his law practice as a sole proprietor from 1972 until 1981. In June of 1981, petitioner and two other attorneys, James R. Jessup (Jessup) and Robyn Owens (Owens), incorporated Samuel C. Stone & Associates, P.C., which was a professional corporationPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011