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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 corporation
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