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With all due respect; Private Letter Rulings (PLR's) are for the private use of the submitting taxpayer & may not be relied upon by the general public. The reason for this is that, among other reasons, the Service is responding to a specific fact set pertinent, at leat initially to only that taxpayer. That being said, we all rely upon PLR's as at least good guidance to the Service's thinking on a specific matter.

In this case, one needn't rely on a PLR; It has been covered in an IRS regulation for the last 13 years.

In specific, IRS Temp. Reg. §1.163-10T(j)(2)(ii)(3) example 3 covers this precise situation; wherein the Service outlines a circumstance wherein the taxpayer effectively elected to amortize mortgage points instead of deducting all in the year of mortgage acquisition.

I haven't seen the WSJ, nor the article mentioned, not the specific PLR referenced, nonetheless, this one seems pretty clear to me. Although not obvious from the Code & more genralized sources; it is apparent that a taxpayer, when purchasing a residence has an election to either deduct the mortgage points in the first year or amortize the points over the life of the mortgage.

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