Mulholland v. United States

OPINION

REGINALD W. GIBSON, Judge:

INTRODUCTION

Kenneth and Catherine Mulholland, husband and wife (taxpayers/plaintiffs herein), filed the instant tax refund suit on October *25330, 1985, seeking a refund of federal income taxes assessed by the Commissioner of Internal Revenue (Commissioner) against their joint individual income tax returns for taxable years 1981 and 1982. This tax refund suit arose because the Commissioner determined that the method of accounting for deductible interest expense employed by Quincy Associates, Ltd. (Quincy), a partnership,1 Le., pursuant to the Rule of 78’s method,2…