- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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