Samuel C. Stone and Susan C. Stone - Page 2

                                        - 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 corporation           




Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  Next

Last modified: May 25, 2011