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MEMORANDUM FINDINGS OF FACT AND OPINION
CHIECHI, Judge: Respondent determined the following defi-
ciencies in, and accuracy-related penalties on, petitioners'
Federal income tax:
Section 6662(a)2
Year Deficiency Accuracy-Related Penalty
1991 $46,801 $9,360
1992 104,743 20,949
1993 37,149 7,430
The issues remaining for decision are:
(1) Does $268,027.48 of interest paid by petitioners during
1991 to the F.E. Hickman, DDS Orthodontics, Inc., Profit-Sharing
Plan (Hickman corporation profit-sharing plan) qualify as invest-
ment interest within the meaning of section 163(d) for which
petitioners are entitled for the years at issue to deductions
under section 163(a), as limited by section 163(d)? We hold that
it does.
(2) Are petitioners liable for each of the years at issue
for the accuracy-related penalty under section 6662(a)? We hold
that they are to the extent stated herein.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
At the time the petition was filed, petitioner French E.
2 Unless otherwise indicated, all section references are to the
Internal Revenue Code (Code) in effect for the years at issue.
All Rule references are to the Tax Court Rules of Practice and
Procedure.
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