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YAMAMOTO v. COMMISSIONER

Docket No. 29006-81.

51 T.C.M. 1560 (1986)

T.C. Memo. 1986-316

Hirotoshi Yamamoto and Shizuko Yamamoto, v. Commissioner.

United States Tax Court.

Filed July 28, 1986.

Attorney(s) appearing for the Case

Hirotoshi Yamamoto, pro se. Henry E. O'Neill, for the respondent.

Memorandum Findings of Fact and Opinion

WILBUR, Judge:

Respondent determined the following deficiencies in petitioners' Federal income taxes:

          Year                           Deficiency
          1978 ........................  $77,684.88
          1979 ........................   82,659.55

The issues for decision are: (1) whether interest petitioners paid during 1978 and 1979 was "investment interest" as defined...

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