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7-67

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Submitted By ent3rix
Words 307
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Mark Hancock, Attorney
Hancock Law Practice
Dear Mr. Hancock:
Thank you for contacting our office regarding your recent tax issues.
In your inquiry you asked whether or not you are eligible to deduct the interest of $18,000 derived from previous tax owed. The $18,000 interest expense will be deemed deductible.
In reaching this conclusion we consulted relevant Internal Revenue Code (“IRC”), applicable Treasury Regulations under IRC, and a relative court case.
The facts as we understand them are as follows: The IRS disallowed several business deductions from 2010 and 2011. Upon this disallowance you were assessed interest owed on back-taxes. You were assessed $18,000 in interest on the taxes owed.
Under the IRC Sec. 163 interest expense is deductible if “interest paid or accrued on indebtedness is properly allocable to trade or business”.
Clearly, the interest expense is derived from trade or business. The trade s Mr. Hancock’s law practice and the deficiencies and interest assessed were a direct result of business activity.
We suggest that you deduct the interest expense of $18,000 on your 2012 return and consult with us for future tax preparation to assure you do not experience any similar situations in the future.
Please call us at 555-555-555 if you have any further questions. May I suggest you visit our office to prepare your 2012 return when you are ready.
To comply with requirements imposed by the Department of the Treasury, we inform you that any
U.S. tax advice contained in this communication (including any attachments) is not intended or written by the practitioner to be used, and that it cannot be used by any taxpayer, for the purpose of (i) avoiding penalties that may be imposed on the taxpayer, and (ii) supporting the promotion or marketing of any transactions or matters addressed

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