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TEDORI v. U.S.

No. 98-56049.

211 F.3d 488 (2000)

Frederick J. TEDORI, Robin J. Tedori, Plaintiffs-Appellants, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Ninth Circuit.

Filed May 1, 2000.

As Amended May 18, 2000.

Attorney(s) appearing for the Case

Denton N. Thomas and Susan Gorman, Andrews & Kurth, Houston, Texas, and William H. Lancaster, Andrews & Kurth, Los Angeles, California, for the plaintiffs-appellants.

Jonathan S. Cohen, Tamara W. Ashford, Tax Division, United States Department of Justice, Washington, D.C., for the defendant-appellee.

Before: PREGERSON and WARDLAW, Circuit Judges, and SHADUR, District Judge.

SHADUR, District Judge:

Taxpayers Frederick and Robin Tedori (collectively "Tedoris"), sole shareholders of an Interest Charge Domestic International Sales Corporation ("DISC"), have claimed as a deduction on their 1989 and 1990 joint federal income tax returns the interest they had paid to the United States on the deferred amounts of their DISC-related tax liability. This litigation stems from the Government's denial of those deductions on the premise that the interest...

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