Wagoner v. Comr., T.C. Sum. Op. 2013-14

(petitioner, a lawyer in Grand Island, NE, failed to pay income tax for seven years resulting in IRS lien on principal residence; petitioner attempted to deduct interest and penalties as qualified residence interest under I.R.C. Sec. 163(h)(3)(A); court rejected petitioner's claim because neither lien nor filing of notice of lien caused the tax indebtedness to be secured by principal residence, and such interest is personal interest in any event; accuracy-related penalties imposed).