Legal Opinion

Lenz v. Commissioner

United States Tax Court

Decided September 30, 1993No. Docket No. 9709-91Published

In each of the years 1981, 1982, 1983, 1984, and 1986, Ps incurred investment interest expense in excess of the amount in which such interest was currently deductible under sec. 163(d), I.R.C. Ps claimed in each year a deduction for investment interest under sec. 163(d) in amounts equal to their net investment income plus $ 10,000 ($ 25,000 in 1983 and 1984) and carried over the excess to succeeding years.

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In each of the years 1981, 1982, 1983, 1984, and 1986, Ps incurred investment interest expense in excess of the amount in which such interest was currently deductible under sec. 163(d), I.R.C. Ps claimed in each year a deduction for investment interest under sec. 163(d) in amounts equal to their net investment income plus $ 10,000 ($ 25,000 in 1983 and 1984) and carried over the excess to succeeding years. The carryover amounts exceeded Ps taxable income in years 1981, 1982, 1983, 1985, and 1986. In 1987, Ps had sufficient net investment income and taxable income to take full benefit of the…

1Opinion of the Court

Randolph W. Lenz and Karin Lenz, Petitioners v. Commissioner of Internal Revenue, Respondent

Lenz v. Commissioner

Docket No. 9709-91

United States Tax Court

101 T.C. 260; 1993 U.S. Tax Ct. LEXIS 58; 101 T.C. No. 17;

September 30, 1993, Filed

Decision will be entered under Rule 155.

In each of the years 1981, 1982, 1983, 1984, and 1986, Ps incurred investment interest expense in excess of the amount in which such interest was currently deductible under sec. 163(d), I.R.C. Ps claimed in each year a deduction for investment interest under sec. 163(d) in amounts equal to their net investment income plus…

Also in this document: Concurrence; Dissent.

2Cases cited20 opinions

  1. United States v. American Trucking AssociationsSupreme Court of the United States · 1940
  2. Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
  3. United States v. LockeSupreme Court of the United States · 1985
  4. Crooks v. HarrelsonSupreme Court of the United States · 1930
  5. Helvering v. Stockholms Enskilda BankSupreme Court of the United States · 1934

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