Several years ago, Carol Mutter, a cash-basis taxpayer, obtained a mortgage from Weak National Bank to purchase a personal residence. In December 2009, $8,500 of interest was due on the mortgage, but Carol had only $75 in her checking account. On December 31, 2009, she borrowed $8,500 from Weak Bank, evidenced by a note, and the proceeds were deposited in her checking account. On the same day, Carol issued a check in the identical amount of $8,500 to Weak Bank for the interest due. Is the interest expense deductible for the 2009 tax year?

Prepare (in good form) a research memorandum to the file. (See Chapter 2 for an illustration of the structure of a tax memo.)