context: This is surely not what the statute intended, and we don't understand the Tax Court or the IRS to say otherwise. Quite to the contrary, both acknowledge that the parentheticals' lower limits apply per spouse -- which is just another way of saying per taxpayer.
citation_a.signal: see
citation_a.parenthetical: interpreting the married-person par-entheticals to mean that "married taxpayers who file separate returns are limited to acquisition indebtedness of $500,000 each " and "to home equity indebtedness of $50,000 each " (emphasis added
citation_a.sentence: See Sophy, 138 T.C. at 212 (interpreting the married-person par-entheticals to mean that “married taxpayers who file separate returns are limited to acquisition indebtedness of $500,000 each ” and “to home equity indebtedness of $50,000 each ” (emphasis added)); see also Bronstein v. Comm’r, 138 T.C. 382, 386 (2012) (“[T]he parenthetical indebtedness limitations of section 163(h)(3)(B)(ii) and (C)(ii) are $550,000 for each spouse filing a separate return.” (emphasis added)).
citation_b.signal: see also
citation_b.identifier: 138 T.C. 382, 386
citation_b.parenthetical: "[T]he parenthetical indebtedness limitations of section 163(h)(3)(B)(ii) and (C)(ii) are $550,000 for each spouse filing a separate return." (emphasis added
citation_b.sentence: See Sophy, 138 T.C. at 212 (interpreting the married-person par-entheticals to mean that “married taxpayers who file separate returns are limited to acquisition indebtedness of $500,000 each ” and “to home equity indebtedness of $50,000 each ” (emphasis added)); see also Bronstein v. Comm’r, 138 T.C. 382, 386 (2012) (“[T]he parenthetical indebtedness limitations of section 163(h)(3)(B)(ii) and (C)(ii) are $550,000 for each spouse filing a separate return.” (emphasis added)).