- 4 - Sun elected to report the income from the installment sales using the installment method, as permitted under section 453(l)(2)(B). During each year at issue, petitioner, in his capacity as a shareholder, paid an additional tax equal to the interest on the tax deferred as a result of Aqua Sun's election of the installment method. The amount of interest was determined with reference to petitioners' tax liability for the previous tax year, so that the interest paid in 1993, 1994, 1995, and 1996 related to petitioners' Federal income tax liability on Aqua Sun's installment sales of timeshare units, as reported on petitioners' returns for 1992, 1993, 1994, and 1995, respectively. Petitioners computed the interest on the deferred tax liability in accordance with section 453(l)(3)(B) and reported the interest as a business deduction on Schedule E, Part II, of Forms 1040 for 1993, 1994, 1995, and 1996, in the following amounts: Year Interest Paid 1993 $382,127 1994 563,169 1995 536,124 1996 501,077 In the notices of deficiency, respondent disallowed petitioners' interest deductions in full because petitioners had failed to establish that said interest payments were allowable business interest expense deductions.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011