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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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