James W. Harris and Dorthy R. Harris - Page 9

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          their behalf.  According to petitioners, this amount is not                 
          includable in their gross income because the Turners paid the               
          interest directly to Union Planters.                                        
               We agree with respondent.  Contrary to petitioners'                    
          assertion, the Turners did not pay Union Planters directly.                 
          They remitted their payments to NBA, which collected the payments           
          on behalf of petitioners.  NBA, in turn, remitted the payments to           
          Union Planters to apply to the debt owed it by petitioners.                 
          Instead of requiring that the Turners obtain third-party                    
          financing for their purchase of the home, petitioners personally            
          financed the Turners' purchase, allowing them to wrap their debt            
          to petitioners around the debt that petitioners already owed                
          Union Planters.  In such a wraparound situation, petitioners'               
          gross income includes the interest that the Turners paid NBA on             
          petitioners' behalf.  See sec. 1.61-7(a), Income Tax Regs.                  
          2.  Deductible Rental Loss                                                  
               Respondent determined that petitioners were entitled to                
          deduct only $25,000 of the $73,129 loss that they reported for              
          Harris Enterprises.  Respondent generally determined that                   
          petitioners had not substantiated $42,955 of the expenses which             
          went into the reported loss, and, with respect to the recomputed            
          loss of $30,174, that petitioners were limited by section 469               
          from deducting currently more than $25,000.  Petitioners argue              
          that they should be allowed to deduct the reported loss in full.            






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