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Loria v. Commissioner

T.C. Memo 1995-420; 70 T.C.M. (CCH) 553 (1995)

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Loria v. Commissioner

United States Tax Court
T.C. Memo 1995-420; 70 T.C.M. (CCH) 553 (1995)

Facts

In 1985, Gregg Loria purchased the property located at 22314 Runnymede, Canoga Park, California, primarily because his brother Bruce Loria (plaintiff) lacked sufficient credit to purchase it himself. Gregg was the property’s sole legal owner and the only person obligated on the mortgage loan issued by Freedom Federal Savings Loan (Freedom Federal). Throughout 1989, Bruce resided at the Runnymede property and made at least $13,270.02 in payments to Freedom Federal on his brother’s mortgage. Freedom Federal’s 1989 Form 1098, issued to Gregg, reported $13,575.40 of mortgage interest paid that year. On his 1989 federal income tax return, Bruce claimed deductions for mortgage interest, mortgage points, and real-property taxes related to the Runnymede property. The commissioner of internal revenue (defendant) issued a notice of deficiency disallowing these deductions. Bruce petitioned the tax court for review, arguing that he was entitled to the deductions because he paid those expenses and lived at the Runnymede property during 1989.

Rule of Law

Issue

Holding and Reasoning (Chiechi, J.)

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Casebooks

Federal Income Tax