John L. Seymour - Page 7

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               Interest allocated to a passive activity within the meaning            
          of section 469 will be taken into account in determining the                
          income or loss from such activity and, therefore, is not subject            
          to the limitations of section 163(h).  Sec. 163(h)(2)(C).                   
          However, the interest expense will be subject to possible                   
          disallowance under the passive activity loss limitation of                  
          section 469.                                                                
               For the purposes of applying the passive loss limitation of            
          section 469 and the nonbusiness interest limitations of section             
          163(d) and (h), section 1.163-8T, Temporary Income Tax Regs., 52            
          Fed. Reg. 24999 (July 2, 1987), prescribes rules for the proper             
          allocation of an interest expense.  In general, an interest                 
          expense is allocated in the same manner as the related debt is              
          allocated; i.e., tracing the proceeds of the debt.  Sec. 1.163-             
          8T(a)(3), Temporary Income Tax Regs, supra.  Section 1.163-                 
          8T(c)(1), Temporary Income Tax Regs., 52 Fed. Reg. 25000 (July 2,           
          1987), provides:                                                            

               Debt is allocated to expenditures in accordance with                   
               the use of the debt proceeds and, except as provided in                
               paragraph (m) of this section, interest expense                        
               accruing on a debt during any period is allocated to                   
               expenditures in the same manner as the debt is                         
               allocated from time to time during such period.  Except                
               as provided in paragraph (m) of this section, debt                     
               proceeds and related interest expense are allocated                    
               solely by reference to the use of such proceeds, and                   
               the allocation is not affected by the use of an                        
               interest in any property to secure the repayment of                    
               such debt or interest.  * * *                                          






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