CARPENTER v. COMMISSIONER

Docket No. 65446.

21 T.C.M. 975 (1962)

T.C. Memo. 1962-176

William K. Carpenter and Francis K. Carpenter v. Commissioner.

United States Tax Court.

Filed July 25, 1962.


Attorney(s) appearing for the Case

Kenneth W. Gemmill, Esq., 1600 Three Penn Center Plaza, Philadelphia, Pa., and Gordon W. Gerber, Esq., for the petitioners. Max J. Hamburger, Esq., for the respondent.


Memorandum Findings of Fact and Opinion

BRUCE, Judge:

Respondent determined a deficiency in the income tax of the petitioners for the year 1954 in the amount of $172,254.63. Certain adjustments made by respondent have not been contested. The only issue presented is whether petitioners are entitled to deduct as interest, payments made by the petitioner, William K. Carpenter, to the Old Republic Credit Life Insurance Company in 1954, in the amount of $189...

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