Frederick J. Tedori, Robin j.tedori v. Order and United States of America

SHADUR, District Judge:

Taxpayers Frederick and Robin Tedori (collectively “Tedoris”), sole shareholders of an Interest Charge Domestic International Sales Corporation (“DISC”), have claimed as a deduction on their 1989 and 1990 joint federal income tax returns the interest they had paid to the United States on the deferred amounts of their DISC-related tax liability. This litigation stems from the Government’s denial of those deductions on the premise that the interest paid was non-deductible personal interest under 26 U.S.C. § 163(h). 2 Acting on cross-motions for summary judgment, the…