-372- OPINION A. The Parties’ Arguments The parties disagree whether their off-the-record conference, during which they narrowed the issues then being heard by the Court, included petitioners’ 1986 interest expense deduction of $368,227. Petitioners contend their agreement included the 1986 interest expense deduction, and reference to its inclusion was inadvertently omitted in their representation to the Court. Respondent disagrees and contends that all of the reasons stated in the notice of deficiency for disallowance of the interest expense deduction for 1986 remain in dispute. B. Analysis After the parties’ off-the-record conference described above, counsel for petitioners stated on the record that he believed the parties’ agreement included all adjustments then being considered by the Court and invited counsel for respondent’s position on that assertion. Counsel for respondent did not point out any qualifications, restrictions, or exceptions to any of the adjustments as to which the issues had been narrowed. On brief, respondent takes the position the issues were not narrowed with respect to petitioners’ 1986 interest expense deduction, nor was any agreement reached with respect to that issue.Page: Previous 362 363 364 365 366 367 368 369 370 371 372 373 374 375 376 377 378 379 380 381 Next
Last modified: May 25, 2011