- 38 - and (2) section 1.163-9T(b)(2)(i)(A), Temporary Income Tax Regs.,17 52 Fed. Reg. 48409 (Dec. 22, 1987). See Redlark v. 16(...continued) proceeds are disbursed to the taxpayer, the debt is treated for purposes of this section as if the taxpayer used an amount of the debt proceeds equal to the balance of the debt outstanding at such time to make an expenditure for such property, services, or other purpose. 17 Sec. 1.163-9T(b)(2)(i)(A), Temporary Income Tax Regs., supra, provides as follows: Sec. 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 meaning of sec. 1.168-8T), regardless of the source of the income generating the tax liability. * * * * * * * (ii) Example. A, an individual, owns stock of an S corporation. On its return for 1987, the corporation underreports its taxable income. Consequently, A underreports A’s share of that income on A’s tax return. In 1989, A pays the resulting deficiency plus interest to the Internal Revenue Service. The interest paid by A in 1989 on the tax deficiency is personal interest, notwithstanding the fact that the additional tax liability may have arisen out of income from a trade or business. The result would be the same if A’s business had been operated as a sole proprietorship. (continued...)Page: Previous 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 Next
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