- 6 -
(1996), and that interest paid on individual tax liabilities
relating to income from a sole proprietorship is to be treated as
nondeductible personal interest. Robinson v. Commissioner, supra
at 46-49, 62, 75. Our conclusion in Robinson is in accord with
opinions of the Courts of Appeals for the Fourth, Sixth, Seventh,
Eighth, and Ninth Circuits and is controlling herein. See
Kikalos v. Commissioner, 190 F.3d 791, 798-799 (7th Cir. 1999),
revg. T.C. Memo. 1998-92; McDonnell v. United States, 180 F.3d
721, 723 (6th Cir. 1999); Allen v. United States, 173 F.3d 533,
538 (4th Cir. 1999); Redlark v. Commissioner, 141 F.3d 936, 937-
938, 942 (9th Cir. 1998), revg. and remanding 106 T.C. 31 (1996);
Miller v. United States, 65 F.3d 687, 691 (8th Cir. 1995).
Although strong arguments are available in support of the
claimed deductions at issue herein (see the dissenting opinions
in Robinson v. Commissioner, supra at 96-121), we are compelled
to conclude in the instant case that the $1,527,695 in interest
petitioners paid on their individual income tax liabilities
relating to income from petitioner’s law practice is to be
treated as nondeductible personal interest.
For the foregoing reasons,
Decision will be entered for
respondent.
Page: Previous 1 2 3 4 5 6
Last modified: May 25, 2011