that petitioners' home equity line of credit qualifies as home equity indebtedness under § 163 (h) (3) (C)(i). 5 . The relevant Treasury regulation, 26 C.F.R. § 1.163-1OT, is also silent in this regard. The regulation provides a method of calculating qualified residence interest when the home debt exceeds the applicable debt limits in the statute, see id. § 1.163-10T(e), but it says nothing about how qualified residence interest should be calculated when there are multi-pie co-owners, whether married or unmarried. 6 . For no apparent reason that we can tell, (C)(ii)’s parenthetical is worded differently. It states, "$50,000 in the case of a separate return by a manied individual.” 26 U.S.C. § 163(h)(3)(C)(ii) (emphasis added). 7 . See Pau v. Comm’r, 73 T.C.M. (CCH) 1819, 1826 (1997) (<HOLDING>). 8 . The dissent does not disagree with this
holding that there was no community of interest because the alleged joint venturers did not have an equal proprietary interest and only one of the alleged joint venturers bore the risks and paid the expenses holding a 50 joint interest holding that the owner of an equitable interest in property in the form of a land contract can grant a mortgage on that interest under ohio law holding that a married couple filing a joint return can deduct interest paid on 1 million of acquisition indebtedness holding that expenses bank incurred in protecting its property interest after mortgagors failed to perform including interest accruing thereon was properly included in indebtedness due under mortgage and awarded to bank in foreclosure action