- 2 - 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).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011