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Respondent determined deficiencies in petitioners' Federal
income taxes in the following amounts:
Year Deficiency
1991 $2,676
1992 855
1993 2,446
After concessions by both parties,2 the remaining issue for
decision is whether interest payments made on a promissory note
executed pursuant to a settlement agreement with the U.S.
Department of Health and Human Services qualify as deductible
expenses.
At the time their petition was filed, petitioners resided in
Hillsborough, California. Some of the facts have been stipulated
and are so found. The stipulation of facts and the accompanying
exhibits are incorporated herein by reference.
FINDINGS OF FACT
Petitioner Gerald P. Keane is a physician, and petitioner
Abbe L. Goll-Keane is a registered nurse. Hereinafter references
to "petitioner" refer to petitioner Gerald P. Keane.
2Petitioners concede Schedule C interest deductions for
1991, 1992, and 1993 to Academic Financial Services of $592,
$479, and $317, respectively, and to the University of Rhode
Island of $38, $29, and $16, respectively. Respondent concedes
Schedule C interest paid by petitioners to First Interstate Bank
in 1993 of $1,938.
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