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INDIANA UNIV. RETIREMENT COMMUNITY, INC. v. COMMISSIONER

Docket No. 2493-88.

92 T.C. 891 (1989)

INDIANA UNIVERSITY RETIREMENT COMMUNITY, INC., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed May 8, 1989.

Attorney(s) appearing for the Case

William W. Oliver, for the petitioner.

Elsie Hall, for the respondent.

OPINION

WILLIAMS, Judge.

The Commissioner determined deficiencies in petitioner's excise tax pursuant to section 49401 for 1982 and 1983 in the amounts of $22,446 and $4,834, respectively. The issue we must decide is whether petitioner may deduct certain interest expense from its "gross investment income" as defined in section 4940 to compute "net investment income."

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