Rebecca Bell v. Commissioner of Internal Revenue

Rebecca Bell appeals a decision of the tax court determining that she owes $2,520 more than she paid on her 1974 income tax. The dispute between the taxpayer and the Commissioner of Internal Revenue concerns whether the taxpayer could deduct as interest a portion of an annual installment payment that she paid to the seller and transferor of certain shares of capital stock. The parties agreed that the installment payments would extend over the joint lives of the transferor and his wife — parents of the taxpayer-transferee. The tax court rejected the taxpayer’s claim. Bell v. Commissioner, 76…