Ronald R. Armacost and Cathy L. Armacost - Page 6

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                    (D)  any qualified residence interest (within the                  
               meaning of paragraph (3)), and                                          
                    (E)  any interest payable under section 6601 on                    
               any unpaid portion of the tax imposed by section 2001                   
               for the period during which an extension of time for                    
               payment of such tax is in effect under section 6163 or                  
               6166 or under section 6166A (as in effect before its                    
               repeal by the Economic Recovery Tax Act of 1981).                       
          Sec. 163(h)(2).  The exception relating to investment interest is            
          the basis for petitioner's claim.                                            
               Interest on indebtedness must be allocated in the same                  
          manner as its underlying debt.  Sec. 1.163-8T, Temporary Income              
          Tax Regs., 52 Fed. Reg. 24999 (July 2, 1987).  Underlying debt is            
          allocated by tracing specific disbursements of the proceeds to               
          specific expenditures.  Id.  If the underlying debt is incurred              
          as a personal expenditure, the interest on that debt may not be              
          deducted under section 163 except to the extent such interest is             
          qualified residence interest.  Sec. 1.163-8T(a)(4)(ii), Example              
          (1), Temporary Income Tax Regs., 52 Fed. Reg. 25000 (July 2,                 
          1987).                                                                       
               But if the underlying debt is incurred to acquire investment            
          property, the interest on that debt is deductible under section              
          163 as investment interest.  Sec. 163(h)(2)(B).  Investment                  
          interest is defined as any interest paid on indebtedness properly            
          allocable to investment property.  Sec. 163(d).  Investment                  
          property includes property producing gross income from interest,             
          dividends, annuities or royalties not derived in the taxpayer's              





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