- 10 - Respondent contends that the interest at issue is nondeductible personal interest under section 163(h) and that section 212 does not apply.B. Limitation on the Deduction of Personal Interest Generally, a taxpayer other than a corporation may not deduct personal interest. Sec. 163(h)(1).2 Investment 2Section 163(h) provides in pertinent part: (h) Disallowance of Deductions 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), (B) any investment interest (within the meaning of subsection (d)), * * * * * * * (D) any qualified residence interest (within the meaning of paragraph (3)), and * * * * * * * (3) Qualified Residence Interest.--For purposes of this subsection-- (A) In general.--The term "qualified residence interest" means any interest which is paid or (continued...)Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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