Bronstein v. Commissioner

138 T.C. 382 (2012)

Study Aids
Case Briefs Overview
Casebooks
Case Briefs
B
From our private database of 46,300+ case briefs, written and edited by humans—never with AI.

Bronstein v. Commissioner

United States Tax Court
138 T.C. 382 (2012)

SC

Facts

In 2007, Bronstein (plaintiff) and her father-in-law purchased property as joint tenants for $1.35 million, subject to a mortgage. Bronstein’s husband had no ownership interest in the property. Both Bronstein and her husband used the property as their residence. Bronstein alone made the mortgage payments in 2007; neither Bronstein’s husband nor her father-in-law contributed to the payments. Bronstein and her husband filed married-but-separate federal income tax returns for 2007. Bronstein claimed a qualified residence mortgage interest deduction based on the $1 million acquisition indebtedness limit under 26 U.S.C. § 163. Neither Bronstein’s husband nor her father-in-law claimed a deduction for mortgage interest paid on the property. The Internal Revenue Service (IRS) (defendant) disallowed a portion of Bronstein’s deduction on the ground the deduction exceeded the $1 million acquisition indebtedness limit under § 163. Specifically, the IRS found that the $1 million acquisition indebtedness limit must be split among married couples who live in the residence and file taxes separately. The IRS concluded that the $1 million acquisition indebtedness limit cannot be claimed in full by one spouse. Bronstein appealed.

Rule of Law

Issue

Holding and Reasoning (Goeke, J.)

What to do next…

  1. Unlock this case brief with a free (no-commitment) trial membership of Quimbee.

    You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 805,000 law students since 2011. Some law schools—such as Yale, Berkeley, and Northwestern—even subscribe directly to Quimbee for all their law students.

    Unlock this case briefRead our student testimonials

  2. Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.

    Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students.

    Learn about our approachRead more about Quimbee

Here's why 805,000 law students have relied on our case briefs:

  • Written by law professors and practitioners, not other law students. 46,300 briefs, keyed to 988 casebooks. Top-notch customer support.
  • The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
  • Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
  • Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.

Access this case brief for FREE

With a 7-day free trial membership
Here's why 805,000 law students have relied on our case briefs:
  • Reliable - written by law professors and practitioners, not other law students
  • The right length and amount of information - includes the facts, issue, rule of law, holding and reasoning, and any concurrences and dissents
  • Access in your class - works on your mobile and tablet
  • 46,300 briefs - keyed to 988 casebooks
  • Uniform format for every case brief
  • Written in plain English - not in legalese and not just repeating the court's language
  • Massive library of related video lessons - and practice questions
  • Top-notch customer support

Access this case brief for FREE

With a 7-day free trial membership

Casebooks

Federal Income Tax

Key Terms