Quimbee logo
DMCA.com Protection Status
From our private database of 18,300+ case briefs...

Bronstein v. Commissioner

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


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


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 486,000 law students since 2011. Some law schools—such as Yale, Vanderbilt, Berkeley, and the University of Illinois—even subscribe directly to Quimbee for all their law students. Read 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. Read more about Quimbee.

Here's why 486,000 law students have relied on our case briefs:

  • Written by law professors and practitioners, not other law students. 18,300 briefs, keyed to 985 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.

Questions & Answers

Have a question about this case?

Sign up for a free 7-day trial and ask it

Sign up for a FREE 7-day trial