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$6,000 from Linda Armacost for noninvestment property, and Linda
Armacost is entitled to her one-half community interest of
$248,000 from petitioner for investment property. Linda
Armacost's deficit in investment property nearly equals the
$250,000 promissory note signed by petitioner. Thus we conclude
that the debt is attributable to the acquisition of Linda
Armacost's community share of investment property, and the
interest on that indebtedness is deductible pursuant to section
163(d).
To reflect the foregoing,
Decision will be entered
for petitioners.
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Last modified: May 25, 2011