Raymond T. and Patricia Murphy - Page 1

                                 T.C. Memo. 2006-243                                  

                               UNITED STATES TAX COURT                                

                   RAYMOND T. and PATRICIA MURPHY, Petitioners v.                     
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 3601-03.           Filed November 9, 2006.                  

               Gerald Katz, for petitioners.                                          
               C. Teddy Li, for respondent.                                           

                       MEMORANDUM FINDINGS OF FACT AND OPINION                        

               HOLMES, Judge:  In December 1997, Raymond Murphy sent a                
          check to Philip Hunt for $225,000.  Murphy says the check was for           
          interest that he owed Hunt on two living horses; the Commissioner           
          says the check was a repayment of principal on a dead one.  If              
          Murphy is right, the entire amount is deductible; if he isn’t,              
          none is.                                                                    

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