Question
Discuss the extent to which Section 465 potentially applies to limit the deductions of investor who invests in an apartment house in the following situations:
Discuss the extent to which Section 465 potentially applies to limit the deductions of investor who invests in an apartment house in the following situations:
(1) investor obtains a $200,000 nonrecourse loan from an unrelated commercial bank to purchase the apartment from Seller.
(b) The facts are the same as in (a), above, except that investor obtains the nonrecourse loan from Seller.
(c) The facts are the same as in (a), above, except that investor obtains the nonrecourse loan from her brother (a "related person" under Section 465(b)(3)(C)) who is a commercial lender. The loan is at an interest rate 3% below the market rate of interest.
(d) The facts are the same as in (c), above, except the interest rate on the loan is equal to the market rate of interest.
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