Thomas J. Rosser - Page 12




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               We disagree.  In those cases, the taxpayers’ corporations              
          incurred expenses related to the corporations and not to the                
          taxpayers individually.  We held that those taxpayers could not             
          deduct their corporations’ expenses.  Here, the interest at issue           
          relates to petitioner individually.  Petitioner bought the                  
          nursing homes primarily to provide employment for himself and his           
          wife.  He was personally liable to pay the interest.  We conclude           
          that the interest expense is his and not that of the S                      
          corporations.  See Boseker v. Commissioner, supra; Schanhofer v.            
          Commissioner, supra.  None of the cases that respondent cites               
          involves a taxpayer who borrowed money to buy a business to                 
          provide his livelihood.  We hold that petitioner may deduct the             
          interest that he paid in 1993 and 1994 for loans that he used to            
          acquire, renovate, and operate the nursing homes.                           
               3.   Interest Relating to the Sunbury Building and Heritage            
                    Inn Partnerships                                                  
               Petitioner contends that the interest that he paid on loans            
          used to acquire the Sunbury building and Heritage Inn                       
          partnerships was trade or business interest because he was a                
          general partner of the partnerships and because Financial                   
          Perspectives and the nursing homes had offices in the Sunbury               
          building.  We disagree.                                                     
               Petitioner did not buy interests in those partnerships to              
          provide employment for himself.  The record is not clear about              
          the extent to which he participated in those partnerships.  The             





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