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TAYLOR v. COMMISSIONER

Docket No. 35152-83.

57 T.C.M. 895 (1989)

T.C. Memo. 1989-331

Willis D. Taylor and Sandra B. Taylor v. Commissioner.

United States Tax Court.

Filed July 11, 1989.

Attorney(s) appearing for the Case

Robert E. Johnson, Roger L. Kessler, and Linda S. Nichols, One Indiana Square, Indianapolis, Ind., for the petitioners. Reid M. Huey, for the respondent.

Memorandum Findings of Fact and Opinion

CHABOT, Judge:

Respondent determined deficiencies in Federal individual income tax against petitioners for 1979 and 1980 in the amounts of $7,975 and $8,860, respectively.

After concessions by both sides, the issue for decision is the nature of the deductions to which petitioners are entitled under either section 1621 or section 166, on account of payments made on a promissory note...

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