Felcyn v. United States

FINDINGS OF FACT AND CONCLUSIONS OF LAW

GADBOIS, District Judge.

For purposes of and in support of the Order of Judgment, the court makes the following Findings of Fact and Conclusions of law:

FINDINGS OF FACT

A. The Tax Deduction

1.On her tax return for 1977, plaintiff Gloria Felcyn (“Felcyn”) claimed an investment interest expense deduction of $5,504.00. This deduction was identified as her share of the investment interest expense claimed on the 1977 tax return of Duncan Properties Partnership (“Duncan”) and as a carryover of investment interest expenses claimed by Duncan for 1976. The Internal…