Redlark v. Comm'r
United States Tax Court
Ps deducted the amount of interest on the portion of a deficiency in Federal income tax arising out of adjustments caused by accounting errors of their unincorporated business. They claimed that the interest was properly allocable to business indebtedness and therefore not personal interest under sec. 163(h)(2)(A), I.R.C. R disallowed such deduction on the ground that it was personal interest under sec. 1.163-9T(b)(2)(I)(A), Temporary Income Tax Regs., 52 Fed.
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Ps deducted the amount of interest on the portion of a deficiency in Federal income tax arising out of adjustments caused by accounting errors of their unincorporated business. They claimed that the interest was properly allocable to business indebtedness and therefore not personal interest under sec. 163(h)(2)(A), I.R.C. R disallowed such deduction on the ground that it was personal interest under sec. 1.163-9T(b)(2)(I)(A), Temporary Income Tax Regs., 52 Fed. Reg. 48409 (Dec. 22, 1987), and limited Ps' total interest deduction to the amounts allowed by sec. 163(h)(5), I.R.C.Held, sec.…
1Opinion of the Court
JAMES E. REDLARK AND CHERYL L. REDLARK, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Redlark v. Comm'r
Docket No. 4445-94.
United States Tax Court
106 T.C. 31; 1996 U.S. Tax Ct. LEXIS 2; 106 T.C. No. 2;
January 11, 1996, Filed
Decision will be entered under Rule 155.
Ps deducted the amount of interest on the portion of a deficiency in Federal income tax arising out of adjustments caused by accounting errors of their unincorporated business. They claimed that the interest was properly allocable to business indebtedness and therefore not personal interest under sec. 163(h)(2)(A), I.R.C.…
Also in this document: Concurrence · Foley; Concurrence · Swift; Concurrence · Laro; Dissent · Ruwe; Dissent · Halpern.
2Cases cited63 opinions
- Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc.Supreme Court of the United States · 1984
- Connecticut National Bank v. GermainSupreme Court of the United States · 1992
- Consumer Product Safety Commission v. GTE Sylvania, Inc.Supreme Court of the United States · 1980
- United States v. American Trucking AssociationsSupreme Court of the United States · 1940
- Tennessee Valley Authority v. HillSupreme Court of the United States · 1978
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