Investment Research Associates - Page 374




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          Issue 14.  Whether the Kanters Are Entitled to a Loss From                   
          Computer Leasing Transactions Involving Equitec for 1983 and 1984            
                                       OPINION                                         
               The Kanters claimed on their Federal income tax returns for             
          1983 and 1984 losses of $83,333 and $161,727, respectively, from             
          computer leasing transactions involving Equitec.                             
               In notices of deficiency for 1983 and 1984, respondent                  
          disallowed the losses.  The Kanters introduced no evidence at                
          trial on this issue.  They failed to carry their burden of proof.            
          Accordingly, we sustain respondent's determination.                          
          Issue 15.  Whether the Kanters Are Entitled to Investment                    
          Interest Expense Deductions for 1981                                         
                                       OPINION                                         
               In the notice of deficiency for 1981, respondent determined             
          that the Kanters were not entitled to deduct claimed investment              
          interest expenses from K&D Associates, SLG Partners, and GLS                 
          Associates in the amounts of $21,521, $23,292, and $45,095,                  
          respectively.  SLG Partners, GLS Associates, and K&D Associates              
          were purportedly engaged in the business of purchasing and                   
          leasing computer equipment.  The Kanters claimed deductions for              
          investment interest expenses from those entities in 1981.                    
          The Kanters introduced no evidence on this issue.  Therefore,                
          respondent's determination is sustained.                                     










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