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Commissioner, 101 T.C. 551, 568 (1993) (Chabot, J., dissenting).
Moreover, in cases too numerous to cite, the word "deficiency"
has been treated as embodying such a definition and has
consequently acquired a fixed and settled meaning. Such being
the case, we have every reason to assume that the conference
committee used the word in that sense. See United States v.
Merriam, 263 U.S. 179, 187 (1923); Norfolk S. Corp. v.
Commissioner, 104 T.C. 13, 37 (1995), supplemented by 104 T.C.
417 (1995); cf. St. Paul Fire & Marine Ins. Co. v. Barry, 438
U.S. 531, 541 (1978) ("Congress thus employed terminology that
evokes a tradition of meaning").
In short, we think that when the conference committee used
the phrase "tax deficiencies", it was referring to amounts due by
way of income, estate, and gift taxes. In this context, the word
"generally" in the conference committee report takes on a
significant meaning. It signals that not all interest relating
to income tax, etc., deficiencies are included in "personal
interest". The logical explanation for what is excluded by
"generally" is such interest that constitutes an ordinary and
necessary business expense and is therefore "allocable to an
indebtedness of a trade or business" within the meaning of the
exception clause of section 163(h)(2)(A). To adopt respondent's
position would require us to substitute the word "always" for
"generally" and to expand the interpretation of the word
"deficiencies" beyond its accepted meaning to encompass taxes
other than income, etc., taxes in order to account for the use of
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