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ALLEN v. U.S. EX REL. INTERNAL REVENUE

No. 98-1401.

173 F.3d 533 (1999)

Richard R. ALLEN, Sr., a resident of Fayetteville, NC, Plaintiff-Appellee, v. UNITED STATES of America, acting By and Through the Internal Revenue, Defendant-Appellant.

United States Court of Appeals, Fourth Circuit.

Decided April 20, 1999.

Attorney(s) appearing for the Case

ARGUED: Charles Bricken, Tax Division, United States Department of Justice, Washington, D.C., for Appellant. David D. Dahl, Manning, Fulton & Skinner, P.A., Raleigh, North Carolina, for Appellee. ON BRIEF: Loretta C. Argrett, Assistant Attorney General, Janice McKenzie Cole, United States Attorney, Jonathan S. Cohen, Tax Division, United States Department of Justice, Washington, D.C., for Appellant.

Before WILKINSON, Chief Judge, and ERVIN and WILKINS, Circuit Judges.

OPINION

ERVIN, Circuit Judge:

The Internal Revenue Service (IRS) and taxpayer Allen dispute whether § 163(h) of the Internal Revenue Code (I.R.C.) of 1986 is facially ambiguous, and further, whether Temp. Treas. Reg. § 1.163-9T(b)(2)(i)(A), which prohibits the deduction of individual income tax deficiency interest, is a valid regulation. See I.R.C. § 163(h)(1986); Temp. Treas. Reg. § 1.163-9T (1987). The district court found for...

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