BELL v. COMMISSIONER

Docket No. 4789-79.

76 T.C. 232 (1981)

REBECCA BELL, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed February 18, 1981.


Attorney(s) appearing for the Case

Mark C. Blackwell, Lynn C. Hoover, Thomas E. King, Gregory M. Kratofil, and Tommy W. Taylor, for the petitioner.

Dale P. Kensinger, for the respondent.


WILES, Judge:

Respondent determined a $2,520 deficiency in petitioner's 1974 income tax. The sole issue for decision is whether petitioner, the obligor under a private annuity agreement, is entitled to an interest expense deduction for 1974 under section 1631 for any portion of the annual payment made pursuant to the private annuity agreement.

FINDINGS OF FACT

All the facts have been stipulated and are found accordingly...

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