- 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 Next
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