Court of Appeals for the Ninth Circuit November 22, 1978, 77-1566 (James v. And Esther R. Cole, and Clifford M. And Elizabeth A. Cole v. Commissioner of Internal Revenue)

EUGENE A. WRIGHT, Circuit Judge:

James and Esther Cole and Clifford and Elizabeth Cole (Coles) appeal a Tax Court decision upholding the disallowance of prepaid interest deductions by the Commissioner of Internal Revenue (Commissioner). The Commissioner required the Coles to deduct interest ratably over the 40-month period for which it was paid. We affirm.

I.