Legal Opinion

Nick Kikalos and Helen Kikalos v. Commissioner of Internal Revenue

Court of Appeals for the Seventh Circuit

Decided September 8, 1999No. 98-2631, 98-2632PublishedCited by 38 opinions

1Opinion of the Court

ILANA DIAMOND ROVNER, Circuit Judge.

On then- income tax returns for 1992 and 1994, Nick and Helen Kikalos deducted as a business expense the interest they paid on tax deficiencies that had been assessed for prior years. The Internal Revenue Service disallowed the deduction pursuant to a temporary regulation that deems interest owed on tax underpayments to be nondeductible personal interest, even if the income giving rise to the tax liability derives from the taxpayer’s business. See Temp. Treas. Reg. § 1.163 — 9T(b)(2)(i)(A), 26 C.F.R. § 1.163-9T(b)(2)(i)(A). Following its decision in Redlark…

2Cases cited28 opinions

  1. Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc.Supreme Court of the United States · 1984
  2. Welch v. HelveringSupreme Court of the United States · 1933
  3. James v. United StatesSupreme Court of the United States · 1961
  4. United States v. CorrellSupreme Court of the United States · 1967
  5. Compañia General De Tabacos De Filipinas v. Collector of Internal RevenueSupreme Court of the United States · 1927

23 more not listed; retrieve them via the Exa API.

3Cited by38 opinions

  1. Square D Company and Subsidiaries v. Commissioner of the Internal Revenue ServiceCourt of Appeals for the Seventh Circuit · 2006
  2. Beard v. COMMISSIONER OF INTERNAL REVENUECourt of Appeals for the Seventh Circuit · 2011
  3. Alfaro v. CommissionerCourt of Appeals for the Fifth Circuit · 2003
  4. Nick Kikalos and Helen Kikalos v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 2006
  5. Juan Amaya v. Jeffrey RosenCourt of Appeals for the Fourth Circuit · 2021

33 more not listed; retrieve them via the Exa API.

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