United States v. Wharton

RIVES, Circuit Judge.

This appeal involves federal income taxes for the calendar years 1946, 1947 and 1948 and presents one single question: Whether interest paid on an in-

debtedness secured by a mortgage on rental property is deductible from gross income in determining adjusted gross income under Section 22(n) (4) of the Internal Revenue Code 1 where there is no showing by the taxpayer that the proceeds of the mortgage were used, or the taxpayer’s obligation incurred, in connection with the rental property or with the production of income therefrom. All interest, with certain exceptions not…