Beyer v. Commissioner
United States Tax Court
Petitioners carried over investment interest expense, paid in 1981, not allowable as a deduction in that year by reason of the limitation contained in sec. 163(d), I.R.C. 1954, but not in excess of taxable income for 1981, to 1982. They then carried over to 1983 the aforesaid 1981 excess investment interest expense and the excess investment interest expense paid in 1982 which was not allowable as a deduction in that year by reason of the limitation contained in sec. 163(d).…
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Petitioners carried over investment interest expense, paid in 1981, not allowable as a deduction in that year by reason of the limitation contained in sec. 163(d), I.R.C. 1954, but not in excess of taxable income for 1981, to 1982. They then carried over to 1983 the aforesaid 1981 excess investment interest expense and the excess investment interest expense paid in 1982 which was not allowable as a deduction in that year by reason of the limitation contained in sec. 163(d). The amount carried over was in excess of petitioners' taxable income for 1982. Held, that the 1982 investment interest…
1Opinion of the Court
OPINION
Tannenwald, Judge:
Respondent determined deficiencies in petitioners’ Federal income tax for the taxable year 1983 in the amount of $38,308 and in the amount of $264 for the taxable year 1984 and an addition to tax under section 66611 in the amount of $9,577 for the taxable year 1983. Respondent having conceded the addition to tax and petitioners having conceded respondent’s determination for 1984, the issues for decision are: (1) Whether petitioners are entitled to a carryover of the amount of investment interest expense for 1981 and 1982 disallowed by reason of the limitations in…
2Cases cited11 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Stubbs, Overbeck & Associates, Inc. v. United StatesCourt of Appeals for the Fifth Circuit · 1971
- Richard J. Todd and Denese W. Todd v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1988
- Todd v. CommissionerUnited States Tax Court · 1987
- King v. CommissionerUnited States Tax Court · 1987
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3Cited by12 opinions
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- O'Rourke v. CommissionerUnited States Tax Court · 1990
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