Edward A. Robinson III and Diana R. Robinson - Page 44




                                       - 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                    






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