- 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.Page: Previous 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 Next
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