Kernrechtsfrage
Whether interest on the land-acquisition mortgage and the increased home mortgage is deductible as debt interest under direct federal tax law.
Extrahierter Entscheid
The interest is not deductible because, in economic terms, it formed part of the acquisition and improvement costs of a unified development project.
Extrahierte Begründung
Debt interest must be interpreted economically. Where loan funds finance land acquisition that is closely connected in time, purpose, and function with the subsequent development, the interest counts as investment cost. The fact that the construction was carried out through a general contractor and the financing was split between two mortgages does not break this unity.