ZIDANIC v. COMMISSIONER

Docket No. 13902-80.

79 T.C. 651 (1982)

JOSEPH A. ZIDANIC, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed October 18, 1982.


Attorney(s) appearing for the Case

J. Ross Haffey, Jr., for the petitioner.

David D. Dahl, for the respondent.


STERRETT, Judge:

By notice of deficiency dated April 14, 1980, respondent determined a deficiency of $47,560 in petitioner's Federal income tax for the taxable year 1977. The sole issue for decision is whether petitioner is entitled to an interest deduction of $92,375 in 1977, or whether such amount must be prorated under section 461(g), I.R.C. 1954.

FINDINGS OF FACT

Some of the facts have been stipulated and are so found. The stipulation...

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