Rifkin v. Commissioner

1988 T.C. Memo. 255, 55 T.C.M. 1055, 1988 Tax Ct. Memo LEXIS 278
CourtUnited States Tax Court
DecidedJune 8, 1988
DocketDocket No. 1790-86.
StatusUnpublished

This text of 1988 T.C. Memo. 255 (Rifkin v. Commissioner) is published on Counsel Stack Legal Research, covering United States Tax Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Rifkin v. Commissioner, 1988 T.C. Memo. 255, 55 T.C.M. 1055, 1988 Tax Ct. Memo LEXIS 278 (tax 1988).

Opinion

PAUL N. RIFKIN AND IRENE S. RIFKIN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Rifkin v. Commissioner
Docket No. 1790-86.
United States Tax Court
T.C. Memo 1988-255; 1988 Tax Ct. Memo LEXIS 278; 55 T.C.M. (CCH) 1055; T.C.M. (RIA) 88255;
June 8, 1988.
Darron C. Knutson, for the petitioners.
John C. Schmittdiel, for the respondent.

WELLS

MEMORANDUM FINDINGS OF FACT AND OPINION

WELLS, Judge: Respondent determined deficiencies in petitioners' 1980 and 1981 Federal income tax in the respective amount of $ 9,216 and $ 6,451. The issue for decision is whether section 265(2)1 causes interest paid on a bank loan secured by municipal bonds*279 to be nondeductible.

FINDINGS OF FACT

Some of the facts have been stipulated and are found accordingly. The stipulation of facts and attached exhibits are incorporated herein by the reference.

When petitioners filed their petition, they resided in Mendota Heights, Minnesota.

Since the early 1960's, petitioner Paul Rifkin (hereinafter individually referred to as petitioner) has been a director of Drovers State Bank South St. Paul (the "Bank"). 2 During the years in issue, petitioner maintained checking and savings accounts at the Bank. On December 24, 1979, petitioner borrowed $ 118,000 from the Bank (the "Loan"). Petitioner used the funds from the Loan to purchase two condominium units for investment purposes in Winter Park, Colorado.

As evidence of the Loan, petitioner executed a note containing the following provision:

2. Security and*280 Set-Off. To secure payment of the indebtedness evidenced by this Note and all other indebtedness, liabilities and obligations of Debtor to Secured Party, whether now existing or hereafter arising and whether direct or indirect, due or to become due, absolute or contingent, primary or secondary, or several or joint and several (all such indebtedness, liabilities, and obligations are herein collectively called "Obligations"), Debtor hereby grants to Secured Party a security interest under the Uniform Commercial Code (hereinafter called "Security Interest") in, and also a general lien upon, the following property:

Various Municipal Bonds

and all other property of every kind of description of the Debtor, which may now or hereafter be in the possession or control of the Secured Party for any purpose, together with the proceeds thereof (all such property, including proceeds, being hereinafter called "Collateral"). As further security for payment of the Obligations, Secured Party has the right, in the event of Buyer's default, to set-off against the Obligations any amount then owed by Secured Party to Buyer.

Interest on the municipal bonds described as collateral in that note*281 provision was exempt from Federal income tax. At the time of the Loan, the municipal bonds were then being held on petitioner's behalf by the Bank.

The Bank's credit file on petitioner contained the following comments:

12-24-79 Today after Board of Directors approval on Friday, I have advanced Mr. Rifkin $ 118,000 secured by a Municipal Bond in the amount of $ 125,000, (bearer bond) for a period of three years, rate of interest 12 percent, payments of $ 39,000 each on December 31, 1980 and 1981 and the balance of $ 40,000 due December 31, 1982. Funds were used to allow Mr. Rifkin to purchase two condominiums in Colorado for speculation and possible resale. Total amount owing is $ 118,000.

On their 1980 and 1981 tax returns, petitioners took deductions for interest paid on the Loan in the respective amounts of $ 14,470 and $ 9,480. In the notice of deficiency, respondent disallowed those deductions in their entirety.

OPINION

We must determine whether any of the interest paid by petitioner on the Loan is deductible. In support of his case, petitioner makes several arguments. His primary argument is that he has shown compelling non-tax reasons for maintaining his*282 investment in tax-exempt securities, and as such, he is not subject to the general rule of section 265(2) which disallows deductions for interest paid on loans relating to tax-exempt securities. Petitioner suggests that the Loan was secured by tax exempt securities for two "non-tax reasons." First, Federal Reserve Board regulations required any loan made to petitioner, a director of the Bank, to have been on terms comparable to loans to third-party borrowers and to have been approved by the Bank's board of directors. 3 Petitioner asserts that he offered the municipal bonds as collateral for the Loan because he wanted to expedite the approval for and processing of the Loan and because he did not want the other directors to delve into his personal financial affairs. Petitioner asserts that by offering the municipal bonds as collateral, (1) he would not have been required to wait for the Bank to investigate and approve as security for the Loan and the use of the investment condominium units in another state, and (2) he need not have disclosed his personal financial affairs to the board, as would have been required before an unsecured loan could have been approved. Second, petitioner*283

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Bluebook (online)
1988 T.C. Memo. 255, 55 T.C.M. 1055, 1988 Tax Ct. Memo LEXIS 278, Counsel Stack Legal Research, https://law.counselstack.com/opinion/rifkin-v-commissioner-tax-1988.