Allie Ray McCullen and Shurley G. McCullen - Page 2

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               After concessions, we must decide:                                     
               1.   Whether petitioner Allie Ray McCullen had a trade or              
          business of developing and selling real estate in 1990 and 1991.            
          We hold that he did not.                                                    
               2.   Whether petitioners may deduct $23,067 for 1990 as                
          interest related to farming.  We hold that they may.  Respondent            
          contends that they may deduct $10,428 for 1990.  Petitioners                
          deducted $20,102 in 1990, but, as discussed below, petitioners              
          paid more farm interest than they deducted.                                 
               3.   Whether petitioners may deduct as interest related to a           
          trade or business the interest paid on a $100,000 loan from South           
          Carolina Bank that they used to buy stock in New-East Bank of               
          Goldsboro (New-East Bank).  We hold that they may not.                      
               4.   Whether petitioners paid $8,126 in interest to First              
          Hanover Bank in 1990, as petitioners contend; $5,443, as                    
          respondent contends; or some other amount.  We hold that                    
          petitioners paid $8,126 in interest to First Hanover Bank in                
          1990.                                                                       
               5.   Whether petitioners are liable for the accuracy-related           
          penalty for negligence under section 6662(a) for 1990 and 1991.             
          We hold that they are.                                                      
               Section references are to the Internal Revenue Code.  Rule             
          references are to the Tax Court Rules of Practice and Procedure.            
          References to petitioner are to Allie Ray McCullen.                         






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