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DAVISON v. COMMISSIONER

Docket No. 15887-94.

107 T.C. 35 (1996)

CHARLES H. DAVISON AND LESSIE B. DAVISON, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed August 26, 1996.

Attorney(s) appearing for the Case

John S. Brown, George P. Mair, William A. Hazel, Matthew D. Schnall, Donald-Bruce Abrams, and Joseph L. Kociubes, for petitioners.

Charles W. Maurer, Jr., for respondent.

OPINION

RUWE, Judge:

Respondent determined deficiencies of $753 and $402,169 in petitioners' 1977 and 1980 Federal income taxes, respectively. After a concession by respondent, the issue for decision is whether White Tail, a general partnership, "paid" interest when it borrowed the funds used to satisfy its interest obligations from the same lender to whom the interest was owed. Petitioner Charles H. Davison was a partner in White Tail, and petitioners...

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