- 3 - deficiencies, and in 1996, petitioners paid to respondent a total of $1,527,695 in accrued statutory interest relating thereto. The parties have stipulated and we find that petitioners’ above income tax liabilities for 1982 through 1988 are properly allocable to petitioner’s law practice. The stipulation reads as follows: The tax compromised by * * * [petitioners and respondent] was tax on income received by Petitioner in his Schedule C law practice for legal fees earned in connection with the settlement of a personal injury lawsuit. As such, the tax arose entirely from Petitioner’s trade or business. On petitioners’ joint Federal individual income tax return for 1996, petitioners claimed an interest expense deduction on Schedule C, Profit or Loss From Business, relating to the above $1,527,695 in interest that petitioners paid to respondent in 1996. After an audit relating to petitioners’ 1996 Federal income tax return, on July 6, 2000, respondent issued to petitioners a notice of deficiency for 1996 in which respondent disallowed the above claimed $1,527,695 interest expense deduction. Discussion Section 163(a) provides generally that taxpayers may deduct interest paid on an indebtedness. Section 163(h)(1), however, provides that individual taxpayers may not deduct “personal” interest.Page: Previous 1 2 3 4 5 6 Next
Last modified: May 25, 2011