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In sum, we hold that petitioners may not deduct the section
453(l)(3)(A) interest on the tax incurred by petitioners on
installment sales of timeshares by Aqua Sun because the interest
is not properly allocable to a trade or business of petitioner,
as required under section 163(h)(2)(A).
Decisions will be entered
for respondent.
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Last modified: May 25, 2011