- 27 - See also Nat Harrison Associates, Inc. v. Commissioner, 42 T.C. at 624-625. Interest withheld by a lender from loan proceeds is nothing more than a promise to pay in the future and does not constitute a payment for purposes of section 163(a). Menz v. Commissioner, 80 T.C. at 1185-1186; Rubnitz v. Commissioner, 67 T.C. 621, 628 (1977); Cleaver v. Commissioner, supra at 454. Based on the foregoing analysis, the interest deductions claimed by White Tail on its 1980 return in the amounts of $1,587,310.46 and $227,647.22 are not allowable, and we sustain respondent's disallowance of the corresponding deductions that petitioners claimed as their distributive share of partnership loss. Decision will be entered under Rule 155.Page: Previous 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27
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