No Double Benefit
No deduction is allowed under this provision for any amount for which a deduction is allowable under any other Code provision. If a deduction for interest on a loan for education expenses is allowable under another provision of the Code, apparently the taxpayer must claim the deduction under that provision even though it may be less advantageous to the taxpayer.
Example – Home Equity Loan - An example of a deduction allowable under another provision might be where a home equity loan is taken out to pay education expenses. However, if the election is made not to treat the loan as qualified home mortgage debt, and the home equity loan were taken out solely for the purpose of paying qualified education expenses, the interest on the loan should qualify for the student loan interest deduction. Note: For years 2018 through 2025 interest paid on home equity debt is generally not deductible for federal as Schedule A home mortgage interest unless the funds were used to make improvements to the home.
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If an individual takes out two separate education loans and the interest on one loan qualifies for deduction under Code § 221, while interest on the other loan qualifies for deduction under some other Code provision, presumably the individual can still take an above-the-line deduction for the maximum amount allowed by the higher education interest rules. The interest deductible under the other provision would not be taken into account in determining whether the maximum deduction allowed under § 221 rules is reached.