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SCHANHOFER v. COMMISSIONER

Docket Nos. 4549-84, 26307-84.

51 T.C.M. 924 (1986)

T.C. Memo. 1986-166

Chester W. Schanhofer and Janet D. Schanhofer v. Commissioner.

United States Tax Court.

Filed April 24, 1986.

Attorney(s) appearing for the Case

Richard W. Pitzner, 150 E. Gilman St., Madison, Wis., for the petitioners. Joseph R. Peters, for the respondent.

Memorandum Opinion

WRIGHT, Judge:

By notice of deficiency dated November 30, 1983, respondent determined deficiencies in petitioners' Federal income taxes for 1979, 1980, 1981 and 1982 in the amounts of $11,037, $7,873, $6,727 and $2,999.99, respectively. The sole issue for decision is whether petitioners are subject to the limitations on interest deductions under section 163(d).1

The facts have been stipulated and are...

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