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STEWART v. COMMISSIONER

Docket No. 11782-77.

41 T.C.M. 318 (1980)

T.C. Memo. 1980-496

Robert E. Stewart and Jo Anne A. Stewart v. Commissioner.

United States Tax Court.

Filed November 4, 1980.

Attorney(s) appearing for the Case

Kim S. La Valley, for the petitioners. Jerome Borison, for the respondent.

Memorandum Findings of Fact and Opinion

GOFFE, Judge:

The Commissioner, in his statutory notice, determined a deficiency of $771 in petitioners' Federal income tax for their taxable year 1975. Due to concessions on their part, the only issue is whether the entire amount of a brokerage commission withheld from the proceeds of a loan obtained by petitioners in 1975 is "interest paid" thereon in that taxable year within the meaning of section 163(a) of the...

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