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FRANKLIN v. COMMISSIONER

Docket No. 9657-78.

77 T.C. 173 (1981)

H. C. FRANKLIN AND MARJORIE FRANKLIN, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed August 4, 1981.

Attorney(s) appearing for the Case

Hubert D. Johnson, for the petitioners.

William P. Hardeman, for the respondent.

CHABOT, Judge:

Respondent determined deficiencies in Federal individual income tax against petitioners for 1973 and 1974 in the amounts of $61,293.85 and $111,465.77, respectively. In connection with issue (2) infra, petitioners claim overpayments for both years. The issues for decision are as follows:

(1) Whether petitioners are entitled to deduct $120,124.99 and $206,414.491 as interest paid for 1973 and 1974, respectively...

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