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determinations are erroneous. Rule 142(a); INDOPCO Inc. v.
Commissioner, 503 U.S. 79, 84 (1992); Welch v. Helvering, 290
U.S. 111, 115 (1933). The parties do not contend otherwise.
Section 163(a) allows individual taxpayers a deduction from
taxable income for interest paid or accrued on indebtedness.
Deductions for "personal interest", however, are not allowed for
individual taxpayers. Sec. 163(h)(1). Section 163(h)(2)(a)
excludes "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)" from the
definition of "personal interest" in section 163(h)(1). Section
163(h) does not directly address whether "personal interest"
includes interest paid on Federal income tax deficiencies.
We have held that interest paid on delinquent Federal income
tax liabilities is personal interest and nondeductible under
section 163(h) where the interest is not proved to be a normal or
usual incident of a business. See Tippin v. Commissioner, 104
T.C. 518, 529 (1995). In Tippin, the record was silent as to the
source of income or other circumstances that gave rise to the
underlying income tax deficiency. Id. at 530. In the instant
case, the record fails to disclose that the interest paid on
petitioners' delinquent income tax liabilities was attributable
to indebtedness allocable to a trade or business or to their
investment activity. Because, as in Tippin, the instant record
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