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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 any
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