- 17 - 1999 2000 2001 Investment interest expense $63,807 $92,036 $2,779 Disallowed investment interest expense from prior taxable year —-- 58,668 146,217 Total investment interest expense 63,807 150,704 148,996 Gross income from property held for investment 5,139 4,487 453 Net gain from the disposition of property held for investment --- --- --- Net investment income 5,139 4,487 453 Disallowed investment interest expense to be carried forward to the next taxable year 58,668 146,217 148,543 Investment interest expense deduction 5,139 4,487 453 D. Conclusion We hold that “net gain”, as that term is used in section 163(d)(4)(B)(ii)(I), requires inclusion of petitioners’ capital losses and capital loss carryovers for purposes of calculating the section 163(d)(1) limitation on the investment interest expense deduction. We hold further that petitioners’ investment interest expense deductions for 1999, 2000, and 2001 are limited to $5,139, $4,487, and $453, respectively. In view of the foregoing, we sustain respondent’s determination on the disputed issue. We have considered all of the other arguments made by petitioners and, to the extent that we have not specifically addressed them, we find them to be without merit.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
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