How have courts rejected a claim for an interest deduction under the Burgess rule?

Battelstein v. Internal Revenue Service, 631 F.2d 1182, 1184 (5th Cir. 1980) (en banc), cert. denied, --- U.S. ----, 101 S.Ct. 2018, 68 L.Ed.2d 325 (1981). In Battelstein, the court flatly rejected a claimed interest deduction where the borrower issued a check to the lender in the amount of the interest due and the lender, in return, loaned the borrower an amount sufficient to cover the interest payment. The court found it unnecessary to consider the continued viability of the Burgess rule, as the loans at issue were "plainly for no purpose other than the repayment of interest." Id. at 1184-85.