Can a participant under the "purchase of pimary residence" safe harbor borrow to buy property that home will be built on? Wants to amortize for 10 yrs.

The home loan exception to the five year repayment rule provides that the five year limit "shall not apply to any loan used to acquire any dwelling unit . . ." (sec. 72(p)(2)(B)).

Purchase of land to build on doesn't appear to fit the bill.

For what it's worth, an National IRS representative also expressed the belief that a loan to cover the materials to build a house would not qualify for a longer pay-back period where the borrower was going to build the house himself. His reasoning was that the dwelling unit couldn't be acquired until it was built.