BRONSTEIN V. COMMISSIONER
138 T.C. 382 (2012)
NATURE OF THE CASE: Bronstein (P) challenged a determination of a deficiency in that the
IRS (D) claimed that P improperly deducted certain home mortgage interest paid.
FACTS: P was married throughout 2007. P and her father-in-law, Michael Bronstein
(father-in-law), purchased real property as joint tenants with right of survivorship. The
price was $1.35 million. P and her father-in-law each signed and became liable on a mortgage
for $1 million (mortgage) secured by the property. P paid $2,500 for a loan discount
(points) at the time of closing. P and her husband resided at the property, which was their
principal residence for tax purposes. P's father-in-law never resided at the property. P
used her own funds to make all payments on the mortgage; neither her husband nor her
father-in-law made any payments on the mortgage. P paid $49,739 in interest on the mortgage
during 2007. P elected 'married filing separately' filing status. P deducted $52,239 in home
mortgage interest and points paid. The IRS (D) issued a notice of deficiency and allowed
only $27,506 of her claimed deduction for the home mortgage interest paid. P petitioned.
ISSUE:
RULE OF LAW:
HOLDING AND DECISION:
LEGAL ANALYSIS:
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