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nor expense, both parties characterized this issue as a "not-for-
profit" rental involving the provisions of section 183(b), and we
shall address those issues.
Pursuant to section 183(b), if an activity is not engaged in
for profit, section 183(b) separates the claimed deductions into
two groups. Section 183(b)(1) allows only those claimed
deductions which are not dependent upon a profit objective, e.g.,
interest and taxes. See Brannen v. Commissioner, 78 T.C. 471,
499-500 (1982), affd. 772 F.2d 695 (11th Cir. 1984); Ritter v.
Commissioner, T.C. Memo. 1996-15. Section 183(b)(2) allows the
balance of the deductions that would otherwise be permitted only
if the activity were engaged in for profit, but only to the
extent that the gross income derived from the activity exceeds
the deductions allowed under paragraph (1). See Green v.
Commissioner, T.C. Memo. 1989-436. Depreciation deductions are
subject to the limitations of section 183(b)(2). Sec. 1.183-
1(b)(1)(iii), Income Tax Regs.
A loan summary document from the Community Bank, N.A.
(presumably the successor to the original mortgagor) reflects the
details of a loan to petitioner of $44,000 at a 7.25-percent
interest rate, payable in 180 monthly payments, the first 60 of
which were for $366.57. We attempted to calculate the amount of
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