- 20 - (Vol. 3) 1, 804-806. This provides a broad context in which to evaluate the impact of the exception for interest on an indebtedness allocable to the business. Id. We first address the language of the conference committee report. Respondent argues that the word "generally" was intended only to permit deduction of interest on past-due business taxes, such as sales and excise taxes which the regulations specifically exclude from the definition of personal interest. See sec. 1.163-9T(b)(2)(iii)(A), Temporary Income Tax Regs., 52 Fed. Reg. 48409 (Dec. 22, 1987). On this basis, respondent concludes that section 1.163-9T(b)(2)(I)(A), Temporary Income Tax Regs., is reasonable and that additional proof of reasonableness is provided by the statement in the Joint Committee Staff Explanation. See supra p. 19. This approach is also articulated by the Court of Appeals for the Eighth Circuit in Miller v. United States, 65 F.3d 687 (8th Cir. 1995), holding the temporary regulation valid. We think both respondent and the Court of Appeals for the Eighth Circuit overlook the use of the word "deficiencies" in the sentence in the conference committee report. That word has had a long-established and well-known meaning. It has been described as a "term of art". Bregin v. Commissioner, 74 T.C. 1097, 1101- 1102 (1980), which describes "deficiency" as a term of art represented by statutory definition as "the amount by which the income, gift, or estate tax due under the law exceeds the amount of such tax shown on the return"; see also Estate of Mueller v.Page: Previous 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 Next
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