Cain: Unmarried Couples and the Mortgage Interest Deduction

Patricia A. Cain (Santa Clara) has posted Unmarried Couples and the Mortgage Interest Deduction, 123 Tax Notes 473 (Apr. 27, 2009), on SSRN.  Here is the abstract:

On March 13, 2009, the IRS released Chief Counsel Advisory 200911007, concluding that unmarried co-owners of a residence were limited to mortgage interest deductions on $1 million of acquisition indebtedness. CCA 200911007 reasons that the $1 million limit should be applied per residence rather than per taxpayer. This article criticizes the IRS position.

Prior TaxProf Blog coverage:

• IRS Limits Home Mortgage Interest Deduction for Gay/Lesbian Couples (Mar. 23, 2009)
• McMahon: In Defense of CCA 200911007 (Mar. 25, 2009)
• Cain: In Defense of the Consensus on CCA 200911007 (Mar. 25, 2009)