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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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