Smoker v. Comr., T.C. Memo. 2013-56

(petitioner took out variable rate loan on principal residence with ceiling on monthly payment; if rate causes ceiling to be exceeded, excess interest is capitalized; petitioner, cash basis taxpayer, deducted capitalized interest currently; court disallowed deduction on basis that interest not paid, but merely secured, and "paid or accrued" language of I.R.C. Sec. 163(h) not applicable because amount not actually paid and petitioner on cash method).