- 5 - were placed in a number of alleged trades involving options in U.S. Treasury obligations. These trades were to function as alleged "hedges" against losses in the gold trades. In the present cases, the stipulation of settled issues resolved all the issues before the Court except whether petitioners are entitled to investment interest expense deductions resulting from Peng Partners' participation in the FTI A/C transactions. The investment interest expense deductions in issue are as follows: Year Amount 1977 $6,618 1978 29,957 1979 18,037 1980 17,771 Discussion Respondent's determination that the claimed interest expense deductions are not deductible is presumptively correct, and petitioners bear the burden of proving that respondent's determination is erroneous. Rule 142(a); INDOPCO, Inc. v. Commissioner, 503 U.S. 79, 84 (1992); Welch v. Helvering, 290 U.S. 111, 115 (1933). The fact that these cases are fully stipulated does not relieve petitioners of that burden. Borchers v. Commissioner, 95 T.C. 82, 91 (1990), affd. 943 F.2d 22 (8th Cir. 1991). Section 163(a) generally permits the deduction of "all interest paid or accrued within the taxable year onPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011