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UNIVERSAL RACQUETBALL ROCKVILLE CENTRE CORP. v. COMMISSIONER

Docket No. 30265-83.

52 T.C.M. 143 (1986)

T.C. Memo. 1986-363

Universal Racquetball Rockville Centre Corporation v. Commissioner.

United States Tax Court.

Filed August 11, 1986.

Attorney(s) appearing for the Case

John A. Matthews, Jr., 11 Clinton Avenue, New York, for the petitioner. Laurence D. Ziegler, for the respondent.

Memorandum Opinion

TANNENWALD, Judge:

Respondent determined a deficiency of $24,696 in petitioner's Federal income tax for the taxable year ending June 30, 1980. The issue for decision is whether petitioner is entitled to an interest deduction of $56,551 based on $377,040 of long-term notes or whether such deduction should be disallowed under sections 1631 and 385 since the advances did not constitute debt of petitioner but were...

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