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SALLEY v. COMMISSIONER

Docket No. 4852-68.

55 T.C. 896 (1971)

RUFUS C. SALLEY AND BEULAH S. SALLEY, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed March 15, 1971.

Attorney(s) appearing for the Case

J. L. Rothchild, for the petitioners.

Arthur B. Bleecher, for the respondent.

FEATHERSTON, Judge:

Respondent determined deficiencies in petitioners' Federal income tax for 1964, 1965, and 1966 in the amounts of $6,264.77, $7,368.09, and $8,883.11, respectively. The only issue presented for decision is whether certain payments made by petitioners to Houston National Life Insurance Co. during the years in issue are deductible as interest under section 163(a),1 business expenses under section 162(a), or expenses...

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