Bronstein v. Commissioner
United States Tax Court
P obtained a $1 million mortgage to help finance her purchase of a home. Although she was married, P paid the mortgage only with her own funds during 2007. P elected the "married filing separately" filing status on her 2007 tax return and deducted the interest paid on the entire $1 million of mortgage indebtedness.
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P obtained a $1 million mortgage to help finance her purchase of a home. Although she was married, P paid the mortgage only with her own funds during 2007. P elected the "married filing separately" filing status on her 2007 tax return and deducted the interest paid on the entire $1 million of mortgage indebtedness. R issued a notice of deficiency which determined that P was limited to a deduction for interest paid on $500,000 of home acquisition indebtedness plus interest paid on $50,000 of home equity indebtedness as a result of her filing status. Held: Under I.R.C. sec. 163(h)(3)(B)(ii) and…
1Opinion of the Court
OPINION
Goeke, Judge:
Respondent determined a deficiency in petitioner’s 2007 Federal income tax of $8,038 as a result of respondent’s determination that she improperly deducted certain home mortgage interest paid. Respondent also determined an accuracy-related penalty under section 6662(a) 1 of $1,608. 2 The issues remaining for decision are:(1) whether petitioner is entitled to a deduction for interest paid on $1 million of home acquisition indebtedness when she filed her tax return as “married filing separately”. We hold that she is not; and(2) whether petitioner is entitled to a deduction…
2Cases cited17 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- United States v. Ron Pair Enterprises, Inc.Supreme Court of the United States · 1989
- United States v. American Trucking AssociationsSupreme Court of the United States · 1940
- Freytag v. CommissionerSupreme Court of the United States · 1991
- HIGBEE v. COMMISSIONER OF INTERNAL REVENUEUnited States Tax Court · 2001
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3Cited by19 opinions
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