Edward A. Robinson III and Diana R. Robinson - Page 48




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          “that personal income tax obligations are always essentially                
          personal in nature”).  Despite whatever logical conclusions may             
          flow from the Congress’s use of the term “personal interest”, and           
          the Congress’s clearly expressed intention to end the deduction             
          for indebtedness incurred to finance personal consumption                   
          expenditures, the instant case does not turn on whether the                 
          obligation to pay deficiency interest is a “personal obligation”            
          or whether the payment of Federal individual income tax is a                
          personal consumption expenditure.  Indeed, the obligation to pay            
          home mortgage interest is undoubtedly a “personal obligation”,              
          yet that type of interest expense is excluded from the definition           
          of personal interest.  Sec. 163(h)(2)(D).  Moreover, as we noted            
          in Redlark v. Commissioner, 106 T.C. at 42: “To conclude that an            
          income tax deficiency is ipso facto a consumption expenditure               
          begs the issue.”  Accordingly, the determination whether an item            
          of interest is either a “personal obligation” or a “personal                
          consumption expenditure” is not the talisman for purposes of                
          applying section 163(h).  Rather, the controlling inquiry, as               
          framed by the statute itself, is whether the interest in issue is           
          “properly allocable to a trade or business”.  Sec. 163(h)(2)(A).            
               When, as in the instant case, the Congress undertakes to               
          define a term explicitly, “we must follow that definition, even             
          if it varies from that term’s ordinary meaning.”  Stenberg v.               
          Carhart, 530 U.S. 914, 942 (2000); Guerrero-Perez v. INS, 242               






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