- 8 - to make business contacts and to provide funds for the bank investors' needs. Petitioner borrowed $100,000 from South Carolina National Bank to buy New-East Bank stock around 1987. On their income tax returns for 1990 and 1991, petitioners deducted the interest on that loan as a business expense. Petitioner borrowed money from New-East Bank to pay farm expenses. Petitioner sold his New-East Bank stock for a loss of $30,000 to $40,000 in 1994 or 1995. E. Loans From Other Banks In 1990 and 1991, petitioner paid interest on many loans. The loans on which interest was paid, the deductibility of which remains in issue after concessions, are listed in par. A-1 of the opinion. Petitioner used one of the two First American Bank loans in dispute to buy the Bass Town tract. He used the other First American Bank loan as a second mortgage on his satellite office in Onslow County. F. Petitioners' Finances and Bank Accounts Mrs. McCullen had a personal checking bank account into which she deposited her salary. Petitioner had a separate personal bank account. He also had two farm bank accounts and one account for his real estate business. His corporation had one account. Petitioner used money from whichever account had enough money to pay other business expenses. For example, hePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011