Dwight E. and Leslie E. Lee - Page 7

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            the claimed interest deductions at issue because the taxpayer had                         
            failed to prove that the transactions giving rise to such                                 
            deductions had actually taken place.  In one instance, however,                           
            we accepted the taxpayer's representation that he had purchased                           
            silver worth $1,033,280 on October 31, 1975, and simultaneously                           
            agreed to sell the same amount of silver at a price of $1,058,776                         
            on January 6, 1976.  There was thus an indicated gain of $25,496.                         
            The taxpayer borrowed the purchase price from an affiliate of the                         
            promoter.  The taxpayer paid $24,996.81 as interest on that                               
            amount on December 19, 1975.  He paid commissions of another                              
            $662.  The terms of his loan agreement effectively precluded him                          
            from further disposition of either the silver he had purchased or                         
            his contract to sell that silver.  There was thus no way for the                          
            taxpayer to profit from that transaction; his indicated gain of                           
            $25,496 was more than offset by his interest and commission                               
            expenses.  We disallowed the deduction of the interest expense                            
            for 1975.  Quoting Goldstein v. Commissioner, supra at 742, we                            
            stated:  "Section 163(a) does not 'intend' that taxpayers should                          
            be permitted deductions for interest paid on debts that were                              
            entered into solely in order to obtain a deduction."  Julien v.                           
            Commissioner, supra at 509.                                                               
                  We applied the same principle in Sheldon v. Commissioner, 94                        
            T.C. 738, 760-762 (1990).  There the issue was whether certain                            
            repurchase agreements, called "repos", generated interest                                 
            deductions.  A repo is an agreement to finance the purchase of a                          




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