- 12 -
settlement offer sent to them by the IRS which would have allowed
petitioners to deduct interest paid with respect to the property
at issue as a "second home". Petitioners did not respond timely
to the offer. The offer was rescinded by the IRS. Petitioners
did not show at trial that they are entitled to the claimed
deduction. See Rule 142(a); Welch v. Helvering, 290 U.S. 111,
115 (1933).
To reflect the foregoing,
Decision will be
entered under Rule 155.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12
Last modified: May 25, 2011