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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