Alfaro v. Commissioner

349 F.3d 225 (2003)

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Alfaro v. Commissioner

United States Court of Appeals for the Fifth Circuit
349 F.3d 225 (2003)

Facts

Daniel Alfaro (plaintiff) was an attorney who ran his own law practice. The Internal Revenue Service (IRS) (defendant) audited Alfaro’s tax returns for the years 1982 through 1988 and determined that Alfaro had underreported income from his law practice. The IRS issued deficiencies and settled with Alfaro in 1995. Pursuant to the settlement, in 1996, Alfaro paid approximately $1.5 million in accrued statutory interest on the deficiencies. Alfaro claimed a deduction for the interest payment on his 1996 tax return. The IRS determined that the deduction was improper and issued a notice of deficiency for Alfaro’s 1996 taxes. Alfaro petitioned the United States Tax Court. The Tax Court ruled in favor of the IRS, upholding the deficiency, and Alfaro appealed.

Rule of Law

Issue

Holding and Reasoning (Wiener, J.)

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