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The sole issue for decision is whether petitioners are
entitled to an itemized deduction for the year 1999 for
investment interest under section 163(d)(1) in an amount greater
than the amount allowed by respondent in the notice of
deficiency.
Some of the facts were stipulated, and those facts, with the
annexed exhibits, are so found and are incorporated herein by
reference. Petitioners' legal residence at the time the petition
was filed was Ft. Lauderdale, Florida.
Petitioners filed a joint Federal income tax return for
1999. That return included a Schedule A, Itemized Deductions, on
which they claimed a deduction of $47,780 for investment interest
relating to numerous capital gain transactions reflected on
Schedule D, Capital Gains and Losses, of their return. In the
notice of deficiency, respondent determined that petitioners were
entitled to a $225 deduction for investment interest and
disallowed $47,555 of the $47,780 claimed on the return. No
other adjustments were made to petitioners' return.
1(...continued)
without objection from respondent, to remove the case from
consideration under sec. 7463. The Court granted petitioners'
motion, and respondent thereafter filed an answer of general
denial. The deficiency in the notice of deficiency is $13,974.
No concessions have been made by respondent; however, in a
posttrial brief, respondent stated the deficiency to be $13,215
with no concessions or explanation for the $756 discrepancy. The
Court assumes the $13,215 recited in respondent's brief is in
error, and the deficiency at issue is $13,974.
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