No. 81-4425.

683 F.2d 125 (1982)

H. C. FRANKLIN and Marjorie Franklin, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Fifth Circuit.

August 16, 1982.

Attorney(s) appearing for the Case

Hubert D. Johnson, Dallas, Tex., for petitioners-appellants.

John F. Murray, Acting Asst. Atty. Gen., Glenn L. Archer, Jr., Asst. Atty. Gen., Michael L. Paup, Chief Appellate Sec., Tax Div., Dept. of Justice, John H. Menzel, Director, Tax Litigation Div., I. R. S., Jonathan S. Cohen, Gayle P. Miller, Tax Div., Dept. of Justice, Washington, D. C., for respondent-appellee.

Before RUBIN and REAVLEY, Circuit Judges, and HUNTER, District Judge.

ALVIN B. RUBIN, Circuit Judge:

We here consider the deductibility of interest paid by a cash basis taxpayer with money borrowed to fulfill his interest obligations on loans made in participation by a group of banks. The taxpayer borrowed from the lead bank to pay interest due both that bank and the other banks that had participated in loans to him. All parties agree that the portion of the interest payments attributable to the lead bank's share in the loans is not...

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