- 12 - 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. ThePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
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