Alfaro v. Commissioner

WIENER, Circuit Judge:

Petitioners-Appellants Daniel V. Alfaro and Irma L. Alfaro, husband and wife (“Taxpayers”) appeal the ruling of the United States Tax Court (“Tax Court”) in its Memorandum Opinion, 1 upholding the notice of deficiency issued by the Internal Revenue Service (“IRS”) on behalf of Respondent-Appellee, Commissioner of Internal Revenue (“CIR”). That notice of deficiency disallowed the Taxpayer’s claim of a 1996 interest expense deduction of $1,527,695, the amount that they paid in accrued statutory interest that year on an income tax deficiency for a prior year. None dispute…