Lawler v. Commissioner
United States Tax Court
Held: P's interest expense of $ 3,020,740 is deductible as "qualified residence interest" under sec. 163(h)(2)(D), I.R.C.Held, further, P may deduct the $ 53,536 in loan application fees that he paid and forfeited in 1989, under sec. 212, I.R.C.Held, further, P may not deduct any of the $ 16,900 in travel expenses in issue. Held, further, P must report a $ 3,642 short-term capital gain from his trading in currency futures contracts.
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Held: P's interest expense of $ 3,020,740 is deductible as "qualified residence interest" under sec. 163(h)(2)(D), I.R.C.Held, further, P may deduct the $ 53,536 in loan application fees that he paid and forfeited in 1989, under sec. 212, I.R.C.Held, further, P may not deduct any of the $ 16,900 in travel expenses in issue. Held, further, P must report a $ 3,642 short-term capital gain from his trading in currency futures contracts. Held, further, P's 1989 and 1990 legal and other professional fees are deductible under sec. 212, I.R.C., and P may not deduct any of the other expenses reported…
1Opinion of the Court
H. ROGER LAWLER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Lawler v. Commissioner
Docket No. 19653-93
United States Tax Court
T.C. Memo 1995-26; 1995 Tax Ct. Memo LEXIS 29; 69 T.C.M. (CCH) 1699;
January 23, 1995, Filed
Decision will be entered under Rule 155.
Held: P's interest expense of $ 3,020,740 is deductible as "qualified residence interest" under sec. 163(h)(2)(D), I.R.C.Held, further, P may deduct the $ 53,536 in loan application fees that he paid and forfeited in 1989, under sec. 212, I.R.C.Held, further, P may not deduct any of the $ 16,900 in travel expenses in issue.…
2Cases cited26 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Commissioner v. HeiningerSupreme Court of the United States · 1943
21 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- In Re ValeUnited States Bankruptcy Court, N.D. Indiana · 1996