- 2 - 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 taxPage: Previous 1 2 3 4 5 6 Next
Last modified: May 25, 2011