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KISTING v. COMMISSIONER

Docket No. 4818-68.

29 T.C.M. 1087 (1970)

T.C. Memo. 1970-249

Joseph F. Kisting v. Commissioner.

United States Tax Court.

Filed August 31, 1970.

Attorney(s) appearing for the Case

William Elden, 1630 W. 47th, Chicago, Ill., for the petitioner. Walter T. Thompson, for the respondent.

Memorandum Findings of Fact and Opinion

QUEALY, Judge:

Respondent determined a deficiency in the petitioner's income tax for the taxable year 1964 in the amount of $2,221.10.

The sole issue presented for decision is whether the petitioner is entitled under section 1631 to deduct as interest a sum of money deposited in 1964 with the respondent in connection with an offer in compromise of tax, penalties and interest.

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