- 430 - 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.Page: Previous 420 421 422 423 424 425 426 427 428 429 430 431 432 433 434 435 436 437 438 439 Next
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