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JULIAN v. COMMISSIONER

Docket No. 67071.

31 T.C. 998 (1959)

LESLIE JULIAN AND PEARL A. JULIAN, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed February 13, 1959.

Attorney(s) appearing for the Case

Richard W. Wilson, Esq., for the petitioners.

John M. Doukas, Esq., for the respondent.

BRUCE, Judge:

This proceeding involves a deficiency in income tax of $79,526.52 for 1953. The only issue is whether petitioner is entitled to deduct $117,677.11 as interest expense for 1953 pursuant to section 23(b), I.R.C. 1939.

FINDINGS OF FACT.

During the year in issue the principal petitioner, Leslie Julian, and his wife, Pearl, resided in Bristol, Connecticut. They filed a joint income tax return...

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