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MORLEY v. COMMISSIONER

Docket No. 40685-84.

87 T.C. 1206 (1986)

E. DEAN MORLEY AND MERRY MORLEY, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed November 19, 1986.

Attorney(s) appearing for the Case

John P. Dedon, James B. Pittleman, and Dexter S. Odin, for the petitioners.

Clement Shugerman, for the respondent.

TANNENWALD, Judge:

Respondent determined deficiencies in petitioners' Federal income tax in the amounts of $28,006.59 for the taxable year ended December 31, 1980, and $19,827.84 for the taxable year ended December 31, 1981. After concessions by the parties, the sole issue for decision is whether interest paid by petitioners constituted "investment interest," the deductibility of which is limited under section 163(d).1

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