- 24 - previously pointed out, see supra note 3, made no substantive change. Besides the implication from the fact that the regulation was only temporary, 11 months is a relatively short period of time for considering its impact. The second action is a 1990 proposal of the Senate Finance Committee to amend section 163, by eliminating the deduction for corporate taxpayers of interest on income tax deficiencies. In explaining the proposed change of law, the Committee states: Individuals are not permitted to deduct personal interest. For this purpose, personal interest includes interest on underpayment of the individual's income taxes, even if all or a portion of the individual's income is attributable to a trade or business. [136 Cong. Rec. S15711 (Oct. 18, 1990).] First, this statement is not reliable evidence of Congressional approval considering that it is only a proposal entered into the Senate record, and that the provision was not approved by Congress, nor is there any indication that the House of Representatives even reviewed the proposal. Furthermore, the proposed amendment contains an express restriction on the deductibility of deficiency interest, which shows that Congress knew how to restrict the deductibility of interest if it so intended. One final comment. Suppose that the only income reported on the return of petitioners had been Schedule C income from Carrier Communications and that the entire deficiency related to the type of errors that the courts have previously concluded were expected to occur in the ordinary course of business. E.g., Polk v. Commissioner, supra. It would constitute an unrealisticPage: Previous 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 Next
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