Category: Deductions & Credits Subject: Interest Expense Title: Interest on Insurance Policy Loans IRC Sections: 264 Filename: 1296.html Date Produced: 12/95 Copyright 1998, The Tax Resource Group. All rights reserved. Telephone
800-578-3498. Internet: www.taxresourcegroup.com 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. |