- 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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