Allie Ray McCullen and Shurley G. McCullen - Page 18

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          T.C. 105, 124 n.21 (1987).  We may discount testimony which we              
          find to be unworthy of belief, Tokarski v. Commissioner, 87 T.C.            
          74, 77 (1986), but we may not arbitrarily disregard testimony               
          that is competent, relevant, and uncontradicted, Conti v.                   
          Commissioner, 39 F.3d 658, 664 (6th Cir. 1994), affg. 99 T.C. 370           
          (1992) and T.C. Memo. 1992-616; Demkowicz v. Commissioner, 551              
          F.2d 929, 931-932 (3d Cir. 1977), revg. T.C. Memo. 1975-278;                
          Banks v. Commissioner, 322 F.2d 530, 537 (8th Cir. 1963), affg.             
          in part and remanding in part T.C. Memo. 1961-237; Loesch & Green           
          Constr. Co. v. Commissioner, 211 F.2d 210, 212 (6th Cir. 1954),             
          revg. and remanding a Memorandum Opinion of this Court dated                
          December 11, 1952.  Respondent offered no evidence to contradict            
          petitioner's testimony.  Petitioner's testimony was plausible,              
          and, we believe, truthful.                                                  
               Respondent contends that petitioners have not proven how               
          much farm interest they paid because petitioner and his                     
          corporation paid interest.  We disagree.  Petitioners have                  
          conceded that they may not deduct interest that the corporation             
          paid.  We accept petitioner's testimony that he paid the interest           
          at issue and that he used these loans for farming.                          
               2.   Conclusion                                                        
               We conclude that, in addition to the $10,428 for 1990 which            
          respondent concedes, petitioners may deduct the following as farm           
          interest:                                                                   






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