Mulholland v. United States

OPINION

REGINALD W. GIBSON, Judge:

Part A:

Plaintiffs, Kenneth and Catherine Mul-holland (taxpayers herein), filed the instant suit in this court2 on October 30, 1985, seeking a refund of federal income taxes assessed by the Commissioner of Internal Revenue (Commissioner) against their joint income tax returns for the taxable years of 1981 and 1982. This income tax refund suit stems from the Commissioner’s determination that the method of accounting for deductible interest expenses utilized by Quincy Associates, Limited (Quincy), a partnership in which Mr. Mulholland was a limited partner during…