in its 2009 Chief Counsel Advice statement, is both reasonable and persuasive. First, it is consistent with the text of the statute: the language of § 163(h)(3) is reasonably read to establish that the debt limit of $1.1 million per qualified residence applies regardless whether there is one owner or two co-owners. The fact that “acquisition indebtedness” is defined as debt secured by a qualified residence suggests that Congress also contemplated that the “aggregate amount treated as acquisition indebtedness” was also defined with respect to a qualified residence. 26 U.S.C. § 163(h)(3)(B). And the IRS’s interpretation is more persuasive than Voss and Sophy’s interpretation, which would result in a windfall to unmarried taxpayers. See Tablada v. Thomas, 538 F.3d 800, 807 (9th Cir.2008) (<HOLDING>). There is no basis to infer that Congress
holding that the bureau of prisonss method for calculating good time credits was a reasonable interpretation of the statute in part because the plaintiffs contrary method would result in a windfall to prisoners that congress did not intend recognizing this method of submission recognizing this method recognizing offset method holding that where no witness testified in support of a method of calculating consolidated tax savings by determining todays value of past tax savings commissions use of method was improper