- 18 - section 1.163-9T, Temporary Income Tax Regs., can, in any event, be appropriately independently determined. Accordingly, we turn our attention to that task. Section 1.163-9T(b)(2)(I)(A), Temporary Income Tax Regs., provides: (2) Interest relating to taxes--(I) In general. Except as provided in paragraph (b)(2)(iii) of this section, personal interest includes interest-- (A) Paid on underpayment of individual Federal, State or local income taxes * * * regardless of the source of the income generating the tax liability; The only legislative history of section 163(h) which directly addresses the issue involved herein is the conference committee report which states: Under the conference agreement, personal interest is not deductible. Personal interest is any interest, other than interest incurred or continued in connection with the conduct of a trade or business (other than the trade or business of performing services as a[n] employee), investment interest, or interest taken into account in computing the taxpayer's income or loss from passive activities for the year. Personal interest also generally includes interest on tax deficiencies. [H. Conf. Rept. 99-841 at II-154 (1986), 1986-3 C.B. (Vol. 4) 1, 154.] The General Explanation of the Tax Reform Act of 1986, elaborates on this statement by providing as follows: Personal interest also includes interest on underpayment of individual Federal, State or local income taxes notwithstanding that all or a portion of the income may have arisen in a trade or business, because such taxes are not considered derived from the conduct of a trade or business.60 * * * _______ 60 Personal interest does not include interest on taxes, other than income taxes, that are incurred in connection with a trade or business. (For the rule that taxes on net income are not attributable to aPage: Previous 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 Next
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