- 18 - interprets personal interest to include interest paid on individual tax deficiencies. Section 163(h) generally provides: SEC. 163. INTEREST. * * * * * * * (h) Disallowance of Deduction for Personal Interest.-- (1) In general.–-In the case of a taxpayer other than a corporation, no deduction shall be allowed under this chapter for personal interest paid or accrued during the taxable year. (2) Personal interest.–-For purposes of this subsection, the term “personal interest” means any interest allowable as a deduction under this chapter other than–- (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) * * * Section 1.163-9T(b)(2)(i)(A), Temporary Income Tax Regs., supra, provides: Section 1.163-9T. Personal interest (temporary).-- * * * * * * * (b) Personal interest–- * * * * * * * (2) Interest relating to taxes–-(i) In general. Except as provided in paragraph (b)(2)(iii) of this section, personal interest includes interest–- (A) Paid on underpayments of individual Federal, State or local income taxes and on indebtedness used to pay such taxes (within the meaningPage: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
Last modified: May 25, 2011