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had narrowed the issues on all of the adjustments that were then
being heard by the Court. Counsel for respondent expressed no
disagreement with that assertion. Following the colloquy between
counsel for the parties and the Court, the trial resumed with
respect to the remaining issues as to which the parties were
unable to agree: (1) Whether payment of the subject expenses out
of the TACI Special E and PSAC Special accounts represented
payment by the Kanters, and (2) whether the Kanters were entitled
to a deduction for interest payments with respect to property
(the Kanters' personal residence) that was titled in a grantor
trust in which Kanter was the deemed owner.
During and after the trial, the parties filed several
stipulations of settlement. On May 15, 1995, the parties filed a
Stipulation Of Settlement As To Certain Issues Between
Petitioners Burton W. Kanter, Naomi R. Kanter, * * * [IRA], And
Subsidiaries, And Respondent. The May 15, 1995 Stipulation Of
Settled Issues listed a number of adjustments contained in the
notices of deficiency that the parties had settled, including an
“Unreported Fee Income” adjustment for 1986. The 1986 interest
expense the Kanters claimed was not listed among these settled
issues, nor was there any listing of the other Schedule A and
Schedule C expenses identified above for the various years in
question.
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