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HOUSTON v. COMMISSIONER

Docket No. 2224-87.

57 T.C.M. 156 (1989)

T.C. Memo. 1989-175

James E. and Barbara Houston v. Commissioner.

United States Tax Court.

Filed April 18, 1989.

Attorney(s) appearing for the Case

W. Dick Coombs, 2095 E. Ave., Akron, Ohio, for the petitioner. John H. Gadon, for the respondent.

Memorandum Findings of Fact and Opinion

WHALEN, Judge:

The Commissioner determined a deficiency of $33,078.47 in petitioners' 1981 Federal income tax. The sole issue is whether the amount paid by petitioners during such year as interest on indebtedness is deductible in full under section 1621 or section 163(a), as petitioners contend, or whether such amount constitutes "investment interest" within the meaning of section 163(d...

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