- 51 -
F.2d 559 (5th Cir. 1957); Vanicek v. Commissioner, 85 T.C. 731,
743 (1985). We have taken into account the changing nature of
the nursery’s business from primarily B&B to container trees and
the effect on transportation costs as well as labor costs. We
conclude that petitioners may deduct an additional $100,000 for
labor in 1985 and in 1986 and $50,000 for labor in 1987. We are
not persuaded that they are entitled to deduct any additional
transportation expenses.
Interest Income
Petitioners admit making loans and receiving interest
payments beginning with the 1985 taxable year. Their argument is
that not all payments were made in a timely fashion and, thus,
respondent has overstated the amount of interest received.
Respondent obtained copies of some of the borrowers' checks
or other records of payments. They also interviewed the
borrowers. From this information, respondent calculated the
amount of petitioners' mortgage interest income. Petitioners
have submitted no records that they may have kept regarding the
borrowers' repayments of the mortgage loans. Nor have they
testified that any borrowers failed to make the payments used by
respondent in calculating the additional interest income. We are
persuaded that the amounts of interest income determined by
respondent were correct. We sustain respondent's determination
of petitioners' interest income.
Page: Previous 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 NextLast modified: May 25, 2011