mortgage interest, 2 residences

Taxpayer is funding the building of a second home with a loan secured by his first home. 163(h)(3)(B)(i)(II) seems clear that for the interest to be deductible, loan must be secured by the second home. Is anyone aware of any guidance stating otherwise?

Thanks.

I don’t have guidance that states otherwise, but rather, a Tax Court case that confirms your understanding --- Koriakos v. Commissioner, T.C. Summary Opinion 2014-70, a case that can’t be cited as precedent.

https://scholar.google.com/scholar_case?case=15468732820047175607&hl=en&as_sdt=6&as_vis=1&oi=scholarr

Thanks for the confirmation.