- 19 - 1990 Lender Amount New-East Bank (#8501000163, #8501001047, and #7501000074) $5,394 Southern National Bank (#274-114025 and #273-018600) 2,074 Bank of Stanley 1,826 First Citizens Bank 3,345 Total $12,639 Thus, petitioners may deduct total farm interest of $23,067 in 1990. D. Whether Petitioners May Deduct as Trade or Business Interest the Interest They Paid on the $100,000 Loan From South Carolina National Bank Petitioner borrowed $100,000 from South Carolina National Bank to buy stock of New-East Bank. Petitioners contend that the interest they paid on the South Carolina National Bank loan was related to petitioner's trade or business, making the interest deductible under section 163(h)(2)(A). We disagree. Petitioner's purchase of New-East Bank stock was not a trade or business. Petitioner was not continuously and regularly involved in buying stock. Commissioner v. Groetzinger, 480 U.S. at 35. Petitioners contend that petitioner bought the New-East Bank stock to help him make business contacts and to provide a source of funds for his business. Even if this were true, the interest on the loan to buy New-East Bank stock would not be deductible under section 163(h)(2)(A). We are not convinced that the amount of interest petitioner paid to buy the stock bears anyPage: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Next
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