- 55 - petitioners have failed to establish that the Takaos, who owned stock in Norager, were personally liable on the debt to Pier 29, or that they had an interest in the property during the years at issue. Accordingly, we sustain respondent's determination on the investment interest issue for 1988. In light of our holding, we do not address respondent's remaining arguments relating to this issue. 1989 Investment Interest Deduction For 1989, petitioners claim that they are entitled to an investment interest deduction of $38,355, consisting of the carryover of investment interest from 198817 plus $30,000 interest Yoshinori paid to Nakamura on amounts Yoshinori owed Nakamura. Nakamura testified that the $30,000 represented expenses he had incurred relating to an earlier audit that he had 17 In the Government's brief, respondent erroneously stated that the Takaos claimed an investment interest expense deduction of $55,320 on Schedule A--Itemized Deductions of their 1988 return. The Form 4952, Investment Interest Expense Deduction, filed with the Takaos' 1988 return shows "Interest expense on investment debts paid or accrued" in 1988 in the amount of $55,320, "Allowed investment interest expense" in the amount of $49,299, and "Disallowed investment interest expense" in the amount of $6,021. The Takaos reported "Deductible investment interest" in the amount of $49,299 on Schedule A for 1988. The Form 4952 filed with the Takaos' 1989 return shows "Investment interest expense paid or accrued" in 1989 in the amount of $32,334, "Allowed investment interest expense" in the amount of $38,355, and "Disallowed investment interest expense" in the amount of zero. The Takaos reported "Deductible investment interest" in the amount of $38,355 on Schedule A for 1989. Petitioners do not explain the $2,334 discrepancy in the amount of investment interest expense they claimed they paid in 1989 on Form 4952 ($32,334) and the amount they now claim in their brief ($30,000). In light of our holding on the 1989 investment interest deduction, see infra, we do not resolve the discrepancy.Page: Previous 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 Next
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