Saffet and Ana Uslu - Page 9

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          made by them on residences of which legal title was held by a               
          sibling of the taxpayer.  These cases, however, are                         
          distinguishable from the instant case.                                      
               In Golder v. Commissioner, supra, the taxpayers were                   
          guarantors of a debt of their corporation, which debt was also              
          secured by the taxpayers' home.  The Court of Appeals for the               
          Ninth Circuit held that the indebtedness in that case was not               
          that of the taxpayers but, rather, was that of the corporation,             
          and that the taxpayers had merely guaranteed that debt.  That is            
          not the situation in this case.                                             
               In Loria v. Commissioner, supra, and Song v. Commissioner,             
          supra, the taxpayers made mortgage payments on residences upon              
          which legal title was held in each case by the taxpayer's                   
          brother.  In both cases, the taxpayer's brother was also indebted           
          to a third party commercial mortgage lender in connection with              
          such residence.  In both cases, the Court denied mortgage                   
          interest deductions to the taxpayers for the reason that the                
          taxpayers had failed to prove that they held any equitable or               
          beneficial ownership in the residences.  In the cases relied on             
          by respondent, the Court held that the subject indebtedness was             
          not that of the taxpayer, and that the taxpayer did not have an             
          ownership interest in the mortgaged property.                               
               In the instant case, petitioners' agreement with Haluk and             
          Aysun coupled with petitioners' continued occupancy of the Alisal           

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