interest and carrying charges
(2) Interest and carrying charges defined For purposes of paragraph (1), the term “interest and carrying charges” means the excess of— (A) the sum of— (i) interest on indebtedness incurred or continued to purchase or carry the personal property, and (ii) all other amounts (including charges to insure, store, or transport the personal property) paid or incurred to carry the personal property, over (B) the sum of— (i) the amount of interest (including original issue discount) includible in gross income for the taxable year with respect to the property described in subparagraph (A), (ii) any amount treated as ordinary income under section 1271(a)(3)(A) , 1276 , or 1281(a) with respect to such property for the taxable year, (iii) the excess of any dividends includible in gross income with respect to such property for the taxable year over the amount of any deduction allowable with respect to such dividends under section 243 or 245, and (iv) any amount which is a payment with respect to a security loan (within the meaning of section 512(a)(5) ) includible in gross income with respect to such property for the taxable year. For purposes of subparagraph (A), the term “interest” includes any amount paid or incurred in connection with personal property used in a short sale.
26 USC § 263(g)(2)
None identified. Default scope is assumed to be the entire title.