- 390 - adjustments that were then being heard by the Court. Counsel for respondent expressed no disagreement with that assertion. Following the colloquy between counsel for the parties and the Court, the trial resumed with respect to the remaining issues as to which the parties were unable to agree: (1) Whether payment of the subject expenses out of the Administration Co. special E and Principal Services special accounts represented payment by Kanter, and (2) whether the Kanters were entitled to a deduction for mortgage interest payments made with respect to property (the Kanters' personal residence) that was titled in a grantor trust of which Kanter was the deemed owner. Respondent also conceded that Kanter's Schedule C expenses were ordinary and necessary to his business. The Kanters claimed that the Schedule A and Schedule C deductions and expenses disallowed by respondent for the years 1986 through 1989 were paid with Kanter's funds. The Kanters are entitled to mortgage interest and real estate taxes paid on their personal residence titled in Egondale Trust, which was Kanter's grantor trust. OPINION On brief, respondent attempted to retract oral stipulations made on the record that, for purposes of deciding respondent's disallowed Schedule A and C deductions and expenses for the years involved, this Court need only decide whether the funds used toPage: Previous 380 381 382 383 384 385 386 387 388 389 390 391 392 393 394 395 396 397 398 399 Next
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