Under I.R.C. Sec. 163(h), acquisition debt and home equity debt is deductible with the total of the two together not to exceed $1.1 million. Here, the petitioner purchased a California residence in 2004 and resided in it with his wife and children. He moved out in 2006 while his wife and children continued to reside in the home through 2012. The couple was divorced in 2008. In 2005, however, the petitioner and wife purchased another home with the intent of renting it out for weekly vacations and similar events. However, the petitioner and spouse weren't able to rent the property out due to substantial repairs that needed to be done in advance of renting the property. The petitioner lived in the second home while not traveling for work. On their joint return, the petitioner deducted amounts for mortgage interest with respect to the second home. IRS disallowed the deduction and the court agreed. The property was not a rental property and the petitioner continued to reside in the property. While mortgage interest was deducted on the aggregate loan exceeded $1.1 million, the court disallowed the excess amount attributable to the second home and noted that had the parties (who were divorced during the years in issue) each paid interest expense, each of them would have been able to deduct up to $1.1 million in qualifying debt. Hume v. Comr., T.C. Memo. 2014-135.