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The Tax Resource Group: Professional Tax Research Material, Resources, and Consulting

Category: Deductions & Credits
Subject: Interest Expense
Title: Interest on Insurance Policy Loans
IRC Sections: 264
Filename: 1296.html
Date Produced: 12/95

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Regarding your memo of 12/8/95 in reference to the deductibility of interest expense on loans against a life insurance policy which loans were used to fund premiums on the policy, I believe that Section 264 applies and would operate to deny any deduction with respect to this interest. See Section 264(a)(3) and Section 264(c)(1). Please call me at your convenience. I want to make sure I am not missing something.