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ALLEN v. U.S.

No. 5:96-CV-909-F.

987 F.Supp. 460 (1997)

Richard R. ALLEN, Sr., Plaintiff, v. UNITED STATES of America, Defendant.

United States District Court, E.D. North Carolina, Western Division.

December 2, 1997.

Attorney(s) appearing for the Case

David D. Dahl, Manning, Fulton & Skinner, Raleigh, NC, for Plaintiff.

R.A. Renfer, Jr., Asst. U.S. Atty., Office of U.S. Atty., Raleigh, NC, Thomas Holderness, Trial Atty., Tax Div., U.S. Dept. of Justice, Washington, DC, for Defendant.

ORDER

JAMES C. FOX, Chief Judge.

In this action, the plaintiff Richard R. Allen ("Allen"), a cash basis taxpayer, seeks a refund of federal income tax paid for the year 1992. The sole issue in this case is whether Allen may deduct deficiency interest paid in 1992 when the deficiency interest arose from adjustments made by the Internal Revenue Service ("IRS") to items of income generated by Allen's real estate business activities.

I. Findings...

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