The taxpayer borrowed approximately $300,000 and deposited this sum with his law firm. On the same day, he put almost exactly the same amount, received as a distribution from the firm, towards the purchase of a new home for him and his wife. It was not clear in which order the two transactions occurred.
Because the direct use of the borrowed funds was for the purpose of refinancing the taxpayer's partnership account with debt, the interest on the borrowed money was deductible. To hold otherwise would introduce an inconsistency that interest would be deductible where a partner's initial capital investment was financed with borrowed funds, but not where a partner, who originally financed with his own money, later withdrew that money for personal use and refinanced with debt.