Charles H. Davison and Leslie B. Davison - Page 27

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          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.                          





















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