Robinson v. Comm'r
United States Tax Court
P-H operated a law practice as a sole proprietorship at all relevant times. R audited Ps' 1987 joint tax return and made several adjustments to the Schedules A and C attached to this tax return. Ps agreed to R's adjustments and the resulting deficiencies and additions to tax. In 1994, R seized real property that Ps owned; in 1995, R sold the property and applied the proceeds to Ps' underpayment of their 1987 income tax liability and interest thereon.
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P-H operated a law practice as a sole proprietorship at all relevant times. R audited Ps' 1987 joint tax return and made several adjustments to the Schedules A and C attached to this tax return. Ps agreed to R's adjustments and the resulting deficiencies and additions to tax. In 1994, R seized real property that Ps owned; in 1995, R sold the property and applied the proceeds to Ps' underpayment of their 1987 income tax liability and interest thereon. On Schedule C of their 1995 joint tax return, Ps deducted the 1987 underpayment interest that had been thus paid. 1. Held: Insofar as sec.…
1Opinion of the Court
Chabot, Judge:
Respondent determined a deficiency in Federal individual income tax for 1995 against petitioners in the amount of $29,879.2 The issue for decision is whether petitioners may deduct for 1995 the interest they paid in 1995 on their 1987 Federal individual income tax underpayment.3
FINDINGS OF FACT
Some of the facts have been stipulated; the stipulations and the stipulated exhibits are incorporated herein by this reference.
Petitioners Edward A. Robinson III (hereinafter sometimes referred to as Edward), and Diana R. Robinson resided in Louisiana when they filed their petition in the…
2Cases cited51 opinions
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- Russello v. United StatesSupreme Court of the United States · 1983
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Colautti v. FranklinSupreme Court of the United States · 1979
- United States v. CorrellSupreme Court of the United States · 1967
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