Below are info on one of the firm's client. Your Senior Manager has asked you to draft an internal memo discussing the implications of the client. Make sure to discuss Issue, Conclusion, Analysis. The manager has also provided you with some sources to start your research for the client.

Addison Brooks is a self-employed attorney who operates his law practice as an unincorporated sole proprietorship. In 2015, the IRS disallowed several business deductions he took in 2013 and 2014. In addition, to paying the deficient and assessed penalties, he also pays $18,000 in interest on the tax owed. Can he deduct that interest in the current year? A partial list of sources is: 162, 163 Reg. 1.163-9T Kikalos v. Comm., 84 AFTR 2d 99-5933