11 these deductions. Sands offered no evidence to substantiate that Lone Star paid the amounts in dispute. Sands submitted a payment notice addressed to her showing interest due on a loan in which she was the borrower. Petitioners submitted two other statements showing interest paid on a loan to Kips Bay Associates, an entity that Murphy described as an investment of his. There is no evidence that the interest amounts shown on the loan statements were Lone Star's obligations or that Lone Star paid those amounts. There is no evidence that Lone Star paid the "other deductions" during the years in issue. We sustain respondent's determination as to these items. 3. Application of Res Judicata or Collateral Estoppel Sands argues that the terms of two settlements entered into between Murphy and respondent should apply to her as well. Sands argues that the doctrines of collateral estoppel and res judicata bind respondent to this result. We do not agree. Sands rests her argument on two cases filed by Murphy, which involved Murphy's taxable years 1985 and 1986: Murphy v. Commissioner, docket No. 4949-91, and Murphy v. Commissioner, docket No. 5150-91 (docket Nos. 4949-91 and 5150-91). Those cases involved Murphy's deductions associated with Lone Star. Those cases were never tried, and Sands was not a party in either case. Murphy and respondent settled those cases and agreed that no deficiencies in income taxes were due and that no addition to tax under section 6651(a) was due for each of Murphy's taxablePage: 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