Facts. Big Times Communication, Inc. decided to move its headquarters from Newark, NJ to Durham, NC. In order to entice its key employees to make the move the corporation offered a home-buying plan to assist employees in the sale of their personal residences in NJ.

Under the plan, the company would make up to six monthly mortgage payments of up to $2,000 per month while the home was listed for sale. If at the end of six months the house was still on the market, the company would purchase the home for its appraised fair market value.

During the current year, the company purchased the home of its district manager for $585,000, its appraised value. The company paid cash of $185,000 and assumed the first mortgage on the residence of $400,000.

While the home was on the market, the company reimbursed the manager $12,000 (6 months × $2,000) towards the mortgage payments. The company has an offer to sell the home for $500,000. The corporate controller would like your advice regarding the deductibility of the potential $85,000 ($500,000 - $585,000) loss on the sale of the residence, the deductibility of the six mortgage payments made before the residence was purchased $12,000 (6 months × $2,000) and the deductibility of the mortgage payments after the residence was acquired from the manager.