Ezel / IRS Rulings / 200910037

CCA 200910037: A party to a land trust could claim the mortgage interest deduction

Number
200910037
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Interest
Topics
Income and deductions
Code sections
§ 163
Ruling dated
January 7, 2009
Publicly released
March 6, 2009
Source
View Official PDF

Apply this to your situation

This page covers legal advice the IRS Office of Chief Counsel wrote for IRS staff, issued in 2009, which can't be cited as precedent. Ask about your situation and see what the current Code and IRS guidance say, with citations.

Currency note: this determination was released in 2009
Statutory amendments, regulation changes, court decisions, or later IRS guidance may have changed the analysis since then. Treat this page as historical context, not current tax advice. Verify current law before relying on any specific rule, threshold, or position mentioned here.
Not precedent. Under 26 U.S.C. § 6110(k)(3), this written determination may not be used or cited as precedent. It is advice from the IRS Office of Chief Counsel to IRS personnel on the facts they presented, and identifying details were redacted by the IRS before release. The official IRS release (linked on this page as a PDF) is the authoritative source.
About this page: The plain-English summary and ruling snapshot below were written by Ezel based on the official IRS release. The full text is the IRS's own document.
View official IRS release (PDF)

Plain-English summary

Chief Counsel addressed a mortgage interest deduction question involving a land trust. After consulting a colleague, the writer concluded that the redacted party could claim the deduction under Revenue Ruling 92-105. The released email provides no additional facts or analysis and asks the recipient for a view.

Ruling snapshot

  • Question: Could the redacted party claim a mortgage interest deduction in the land-trust arrangement?
  • Outcome: Advice given: yes, under Revenue Ruling 92-105.
  • Key authorities: IRC § 163; Rev. Rul. 92-105.

Full text (IRS public release)

ID: CCA-1071452-09 Number: 200910037
Release Date: 3/6/2009
Office: ----------------
UILC: 163.00-00

From: ------------------
Sent: Wednesday, January 07, 2009 2:52 PM
To: ---------------------------
Cc:
Subject: RE: Land Trust Question

--------

I spoke with my colleague and she agrees that -------------- can claim the mortgage interest deduction
following Rev Rul 92-105. What do you think?

--------

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