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timeshares by A, because the interest is not properly
allocable to a trade or business of P. See sec.
163(h)(2)(A), I.R.C.
John A. Sanders, for petitioners.
William R. McCants, for respondent.
OPINION
NIMS, Judge: In these consolidated cases, respondent
determined the following deficiencies with respect to
petitioners' Federal income taxes:
Year Deficiency
1993 $151,323
1994 223,015
1995 212,305
1996 198,426
Unless otherwise indicated, all section references are to
sections of the Internal Revenue Code in effect for the years in
issue. All Rule references are to the Tax Court Rules of
Practice and Procedure. All dollar amounts are rounded to the
nearest dollar.
The sole issue for decision is the deductibility of interest
paid by Robert W. Carlson (petitioner), an S corporation
shareholder, pursuant to an election under section 453(l)(3)(A)
(relating to installment sales of timeshares and residential
lots).
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