William C. and Cheryl M. Fowler - Page 18




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          interprets personal interest to include interest paid on                    
          individual tax deficiencies.                                                
               Section 163(h) generally provides:                                     
               SEC. 163.  INTEREST.                                                   
                         *    *    *    *    *    *    *                              
                    (h) Disallowance of Deduction for Personal                        
               Interest.--                                                            
                         (1) In general.–-In the case of a taxpayer                   
                    other than a corporation, no deduction shall be                   
                    allowed under this chapter for personal interest                  
                    paid or accrued during the taxable year.                          
                         (2) Personal interest.–-For purposes of this                 
                    subsection, the term “personal interest” means any                
                    interest allowable as a deduction under this                      
                    chapter other than–-                                              
                              (A) interest paid or accrued on                         
                         indebtedness properly allocable to a trade or                
                         business (other than the trade or business of                
                         performing services as an employee) * * *                    
          Section 1.163-9T(b)(2)(i)(A), Temporary Income Tax Regs., supra,            
          provides:                                                                   
               Section 1.163-9T.  Personal interest (temporary).--                    
                              *    *    *    *    *    *    *                         
                    (b) Personal interest–-                                           
                              *    *    *    *    *    *    *                         
                         (2) Interest relating to taxes–-(i) In                       
               general.  Except as provided in paragraph (b)(2)(iii)                  
               of this section, personal interest includes interest–-                 
                              (A) Paid on underpayments of individual                 
               Federal, State or local income taxes and on                            
               indebtedness used to pay such taxes (within the meaning                






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