- 18 -
On May 4, 1987, the staff of the Joint Committee on Taxation
published its “Blue Book”, which included the following:
Personal interest also includes interest on
underpayments 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.
* * *
On June 10, 1987, the chairman and ranking minority member
of each of the tax-writing committees introduced bills to make
technical corrections to TRA 1986. Each bill included the
following:
Subparagraph (A) of section 163(h)(2) of the 1986
Code is amended by striking out “incurred or continued
in connection with the conduct of” and inserting in
lieu thereof “properly allocable to”. [Sec. 105(c)(1)
of H.R. 2636 and S. 1350.]
Each bill provided that the change was to take effect as
though it had been included in TRA 1986. The Ways and Means
Committee report stated that the change in section 163(h)(2)(A)
is intended to make it consistent with the language of section
469, which also had been enacted in TRA 1986. The House of
Representatives passed the provision as part of the 1987 Budget
Reconciliation Act. The Finance Committee approved the same
language and described it the same way in its report.
For reasons unrelated to this provision, the technical
corrections were dropped from the Omnibus Budget Reconciliation
Act of 1987, Pub. L. 100-203, 101 Stat. 1330. The same
provisions were then introduced as part of the Technical
Page: Previous 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 NextLast modified: May 25, 2011