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for obtaining a credit report. Petitioners failed to argue their
entitlement to this amount. We therefore deem it conceded;
$3,008 remains in dispute.
According to the Firemen's Fund Mortgage note, the first
mortgage payment was for interest only and was payable in
advance. It was withheld from the loan proceeds at the close of
escrow. The payment covered the period from December 3, 1986, to
February 1, 1987. This period began 15 days before petitioners
purchased Crow Canyon. They claim that this prior-to-ownership
interest was a loan fee, part of the lender's consideration, and
that they therefore are entitled to include it in basis.
Interest is any amount paid for the use, forbearance, or
detention of money. Old Colony R. Co. v. Commissioner, 284 U.S.
552 (1932). Interest, subject to numerous rules, is usually
deductible rather than capitalized. Petitioners have cited no
section of the Code that would entitle them to capitalize this
preownership interest, and we know of none.
As for the part of the first mortgage payment relating to
the postacquisition period, petitioners claim that the property
was under repair and unproductive. They therefore also
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