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Congress also used varying definitions for these terms, e.g.,
“Interest expense that is paid or incurred in carrying on a trade
or business” (H. Rept. 99-426 at 298, 1986-3 C.B. (Vol. 2) 1,
298), “interest paid or accrued on indebtedness incurred or
continued in connection with–-(i) the conduct of a trade or
business” (H.R. 3838, sec. 1421 (as passed by the Senate), 132
Cong. Rec. at S 8921 (June 26, 1986)).
We make these observations because of the apparent focus on
the question of whether interest paid in respect of an
individual’s Federal income tax liability is a “personal
obligation”. See Miller v. United States, 65 F.3d at 691,
stating:
that an individual’s income tax liability, regardless of the
nature of the income giving rise to the liability, is a
personal obligation and that, consequently, interest owed by
such individual because of a failure to pay his tax
obligation on time necessarily is also a personal
obligation.
See also Kikalos v. Commissioner, 190 F.3d at 797 (describing as
reasonable the view taken by the Secretary therein that interest
on income tax deficiencies is personal interest because the
obligation to pay income tax is personal); Allen v. United
States, 173 F.3d at 537 (stating: “Pursuant to these allocation
rules, deficiency interest is allocable to the payment of income
taxes, an expenditure that is purely personal in nature.”);
Redlark v. Commissioner, 141 F.3d at 941 (agreeing with the
statement of the Court of Appeals for the Eighth Circuit (Miller)
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