Nick Kikalos and Helen Kikalos v. Commissioner of Internal Revenue
Court of Appeals for the Seventh Circuit
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…
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