If the uniform capitalization rules, discussed under
Capitalization of Interest, earlier, do not apply to you,
deduct interest as follows.
Cash method.
Under the cash method, you can generally deduct only the interest
you actually paid during the tax year. You cannot deduct a promissory
note you gave as payment because it is a promise to pay and not an
actual payment.
Prepaid interest.
You generally cannot deduct any interest paid before the year it is
due. Interest paid in advance can be deducted only in the tax year in
which it is due.
Discounted loan.
If interest or a discount is subtracted from your loan proceeds, it
is not a payment of interest and you cannot deduct it when you get the
loan. For more information, see Original issue discount (OID)
under Interest You Can Deduct, earlier.
Refunds of interest.
If you pay interest and then receive a refund in the same tax year
of any part of the interest, reduce your interest deduction by the
refund. If you receive the refund in a later tax year, include the
refund in your income to the extent the deduction for the interest
reduced your tax.
Accrual method.
Under the accrual method, you can deduct only interest that has
accrued during the tax year.
Prepaid interest.
You generally cannot deduct any interest paid before it is due.
Instead, deduct it in the year in which it is due.
Discounted loan.
If interest or a discount is subtracted from your loan proceeds, it
is not a payment of interest and you cannot deduct it when you get the
loan. For more information, see Original issue discount (OID)
under Interest You Can Deduct, earlier.
Tax deficiency.
If you contest a federal income tax deficiency, interest does not
accrue until the tax year the final determination of liability is
made. If you do not contest the deficiency, then the interest accrues
in the year the tax was asserted and agreed to by you.
However, if you contest but pay the proposed tax deficiency and
interest, and you do not designate the payment as a cash bond, then
the interest is deductible in the year paid.
Related person.
If you use the accrual method, you cannot deduct interest owed to a
related person who uses the cash method until payment is made and the
interest is includible in the gross income of that person. The
relationship is determined as of the end of the tax year for which the
interest would otherwise be deductible. If a deduction is denied under
this rule, the rule will continue to apply even if your relationship
with the person ceases to exist before the interest is includible in
the gross income of that person. See Related Persons in
Publication 538.
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