Gerald P. and Abbe L. Keane - Page 10

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          limit or prohibit the taxpayer from deducting indebtedness                  
          interest at all.                                                            
               Section 163(h) provides that for an individual taxpayer,               
          personal interest is nondeductible.  Personal interest is defined           
          in section 163(h)(2) as the residual of what remains after                  
          considering five enumerated exceptions.  These exceptions are:              
                    (A)  interest paid or accrued on indebtedness                     
               properly allocable to a trade or business (other than                  
               the trade or business of performing services as an                     
               employee),                                                             
                    (B)  any investment interest (within the meaning                  
               of subsection (d)),                                                    
                    (C)  any interest which is taken into account                     
               under section 469 in computing income or loss from a                   
               passive activity of the taxpayer,                                      
                    (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).                      

          Section 163(h)(2).                                                          
               The first exception relating to interest paid on a trade or            
          business expense is the only exception that potentially relates             











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