- 3 - Following our consolidation of these cases for purposes of trial, briefing, and opinion, and following our rulings granting respondent's motions for partial summary adjudication, Scherping v. Commissioner, T.C. Memo. 1991-384, and Scherping v. Commissioner, T.C. Memo. 1991-388, we are left to decide the following issues: 1. Whether LaVern Scherping and Loren Scherping may deduct interest expenses in amounts greater than those determined by respondent. 2. Whether LaVern Scherping and Loren Scherping are liable for the additions to tax for negligence determined by respondent under section 6653(a)(1) and (2) for 1984 and 1985 and under section 6653(a)(1)(A) and (B) for 1986. 3. Whether LaVern Scherping and Loren Scherping are liable for the additions to tax for substantial understatement determined by respondent under section 6661. We hold for respondent on all issues. Section references are to the Internal Revenue Code in effect for the years in issue. Rule references are to the Tax Court Rules of Practice and Procedure. The term "petitioners" refers to LaVern Scherping and Loren Scherping collectively. FINDINGS OF FACT Some of the facts have been stipulated and are so found. The stipulated facts and the exhibits submitted therewith arePage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
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