- 98 - Internal Revenue Service.5 It is difficult to imagine that Congress was not aware of the number of individuals engaged in sole proprietorships in 1986. It is even more difficult to comprehend that Congress would deny this large segment of the business world a deduction for interest, which I believe is clearly allocable to a trade or business, without more discussion in the legislative history, or at least a clear directive to the Commissioner to effect such a policy. To permit such a result is to allow the Commissioner to make an end run around the legislative powers of Congress. For the foregoing reasons, I respectfully dissent. SWIFT, COLVIN, LARO, and VASQUEZ, JJ., agree with this dissenting opinion. 5 Statistics of Income Bulletin, Vol. 21, no. 1, from table 1.–Nonfarm sole proprietorships: business receipts, payroll, and net income, by industrial sectors classified with the North American Industries Classification System, Summer 2001.Page: Previous 88 89 90 91 92 93 94 95 96 97 98 99 100 101 102 103 104 105 106 107 Next
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