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Year Amount
1986 $11,995
1987 13,108*
1988 12,067**
1989 25,286
1990 28,988
1991 25,709
1992 28,982
1993 29,398
1994 23,947
* Includes $2,424 in tax-exempt interest.
** Includes $2,452 in tax-exempt interest.
Petitioners reported the following amounts of interest
expense in Schedule A, Itemized Deductions, of their returns for
the years indicated:
Year Amount
1986 $13,688
1987 5,135
1988 6,046
1989 13,570
1990 12,752
1991 9,394
1992 8,040
1993 4,382
1994 4,892
In Forms 1120S, U.S. Income Tax Return for an S Corporation,
for 1992, 1993, and 1994, Paul & Joe, Inc., reported gross
receipts in the amounts of $308,643, $334,427, and $307,478,
respectively. In those forms, Paul & Joe, Inc., reported cost of
goods sold in the amounts of $161,149, $208,999, and $151,120,
respectively, of which $93,478, $117,149, and $90,164, respec-
tively, were reported as "Purchases" and $68,543, $93,125, and
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