- 7 - Commissioner, 118 T.C. 1, 7 (2002) (and cases cited therein); see also City of New York v. Commissioner, 103 T.C. 481, 489 (1994), affd. 70 F.3d 142 (D.C. Cir. 1995). Moreover, even where the statutory language appears clear, we may seek out any reliable evidence as to legislative purpose. City of New York v. Commissioner, supra. 1. Section 163 For individual taxpayers, section 163(a) allows a deduction for all interest paid or accrued within the taxable year on indebtedness. Section 163(d), however, limits the amount of the investment interest expense deduction to the taxpayer’s net investment income for the taxable year.4 In other words, the higher the taxpayer’s net investment income, the more investment interest expense the taxpayer is allowed to deduct for the taxable year. Furthermore, section 163(d)(2) allows the taxpayer to carryforward any investment interest expense disallowed under the general limitation for the taxable year and deduct it as investment interest expense paid or accrued in the succeeding taxable year to the extent that the taxpayer has investment income in that year. 4The Tax Reform Act of 1969, Pub. L. 91-172, sec. 221(a), 83 Stat. 478, 574, originally enacted sec. 163(d) effective for taxable years beginning after Dec. 31, 1971.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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