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T.C. 1107, 1110-1111 (1981) (relating to subchapter S
corporations’ “one-shot” elections); Estate of Beal v.
Commissioner, 47 T.C. 269, 271-272 (1966) (relating to
includability of the value of certain annuities in decedents’
estates). Where the Congress has chosen to so legislate, the
courts do not confine the statute to the original problem, but
rather apply the statute to the net that the Congress has chosen
to cast.
In light of the evolution of section 163(h) over the 4 years
from the Treasury Report to TAMRA 1988, the original objective of
the proposal cannot be taken as sufficiently explaining the
meaning of section 163(h)(2)(A).
(2) The Varying “Handles”; Definition in the Statute
When the Congress enacts a definition of a term, the
statutory definition controls over definitions in general
dictionaries.
A review of the relevant history of the legislation reveals
the varying phraseology that the Congress employed in the
legislative process that culminated in the enactment of section
163(h)(2). Five different terms, or “handles”, were used to
describe the interest, the deductions in respect of which the
Congress wanted to either limit or disallow: “nonbusiness
interest”, “nonbusiness consumer interest”, “consumer interest”,
“personal (consumer) interest”, and “personal interest”. The
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