Robert W. and Janet L. Carlson - Page 2




                                        - 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