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P was married throughout 2007. P and her father-in-law, Michael Bronstein (father-in-law), purchased real property as joint tenants with right of survivorship. The price was $1.35 million. P and her father-in-law each signed and became liable on a mortgage for $1 million (mortgage) secured by the property. P paid $2,500 for a loan discount (points) at the time of closing. P and her husband resided at the property, which was their principal residence for tax purposes. P's father-in-law never resided at the property. P used her own funds to make all payments on the mortgage; neither her husband nor her father-in-law made any payments on the mortgage. P paid $49,739 in interest on the mortgage during 2007. P elected 'married filing separately' filing status. P deducted $52,239 in home mortgage interest and points paid. The IRS (D) issued a notice of deficiency and allowed only $27,506 of her claimed deduction for the home mortgage interest paid. P petitioned.

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