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all Rule references are to the Tax Court Rules of Practice and
Procedure.
After concessions, the remaining issue for decision is
whether petitioners for 1996 are entitled to deduct as
nonpersonal business interest $1,527,695 in interest that
petitioners paid to respondent in 1996 with respect to
petitioners’ Federal individual income tax liabilities for 1982
through 1988.
Background
The facts of this case were submitted fully stipulated under
Rule 122, and are so found.
At the time the petition was filed, petitioners resided in
Corpus Christi, Texas. Hereinafter, all references to petitioner
in the singular are to Daniel V. Alfaro.
During 1982 through 1996 (1996 being the year in issue
herein), petitioner operated a law practice as a sole
proprietorship.
After an audit by respondent with respect to petitioners’
Federal individual income tax liabilities for 1982 through 1988,
respondent determined and assessed against petitioners tax
deficiencies for those years relating solely to additional income
from petitioner’s law practice. In 1995, petitioners entered
into an agreement with respondent with respect to the above tax
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