Edward A. Robinson III and Diana R. Robinson - Page 60




                                       - 34 -                                         
               Thus, it is not clear whether the term “deficiency”, to                
          which we attributed such significance in Redlark v. Commissioner,           
          106 T.C. at 44-45, is merely an inadvertence in one portion of              
          the conference committee report.                                            
               Secondly, the word “generally” may merely serve the function           
          of alerting the reader that there is a category of interest on              
          tax underpayments that does not fit into the definition of                  
          “personal interest”--to wit, the interest described in                      
          subparagraph (E) of section 163(h)(2), as follows:                          
                    (E) any interest payable under section 6601 on any                
               unpaid portion of the tax imposed by section 2001 for the              
               period during which an extension of time for payment of such           
               tax is in effect under section 6163 or 6166.[14]  [Joint               
               Committee staff summary at 18.]                                        
               Thirdly, the Joint Committee staff summary, published 20               
          days before the Conference Report, described the provision as               
          follows:                                                                    
               Interest on underpayments of tax (other than certain                   
               deferred estate taxes) is treated as personal interest                 
               under the provision.                                                   
          Apart from the use of “underpayments” rather than “deficiencies”,           
          the Joint Committee staff summary appears to be completely                  
          consistent with the conference committee sentence on which we               
          focused in Redlark v. Commissioner, 106 T.C. at 44-45--and quite            
          inconsistent with the conclusion we drew in Redlark.                        


               14  The reference to sec. 6166 later was stricken by sec.              
          503(b)(2)(B) of the Taxpayer Relief Act of 1997, Pub. L. 105-34,            
          111 Stat. 788.                                                              





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