Allie Ray McCullen and Shurley G. McCullen - Page 19

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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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