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

Sophy v. Commissioner

United States Tax Court
138 T.C. No. 8 (2012), 138 T.C. 204 (2012)


Charles Sophy and Bruce Voss (plaintiffs) purchased two residences together, each subject to a mortgage. Sophy and Voss owned each residence as joint tenants and were jointly and severally liable for the indebtedness on each residence. Sophy and Voss were not married. The average balance of Sophy and Voss’s indebtedness on the houses was approximately $2.7 million in 2006 and 2007. On their federal income tax returns in 2006 and 2007, Sophy and Voss each claimed qualified residence interest deductions based on the amount of mortgage interest they had paid in each year. Sophy and Voss each claimed the maximum deduction based upon interest paid on $1 million of acquisition indebtedness, Thus, Sophy and Voss claimed the deduction based on a total of $2 million of acquisition indebtedness. The Internal Revenue Service (IRS) (defendant) disallowed portions of these deductions on the ground that the deductions exceeded the $1 million acquisition indebtedness limit under 26 U.S.C. § 163. Sophy and Voss appealed, asserting that the acquisition indebtedness limit applied on a per-taxpayer basis for non-married co-owners. Sophy and Voss thus argued that they each were able to base a deduction on $1 million of acquisition indebtedness.

Rule of Law


Holding and Reasoning (Cohen, 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