David Miller Valeria Miller v. United States

ROSS, Senior Circuit Judge.

Appellants David and Valeria Miller (taxpayers) appeal from a judgment entered in favor of the Government concluding that the taxpayers are not entitled to deduct from their gross income interest arising from an underlying income tax deficiency. After a careful review of the record, briefs and arguments of the parties, we affirm.

I

The taxpayers were assessed federal and state income tax deficiencies for the tax years 1982 and 1983, generated by adjustments to their reported farming income during those years. In 1988, the taxpayers paid $367,332 in interest on those…