- 45 - ________________ 4 For example, an interest deduction that is disallowed under section 265 or 291 should not be allowed, capitalized, or suspended under another provision. The Congress’s suggestion, however, specifically related to the allocation rules for section 469 only; the Joint Statement of Managers portion of the conference committee report does not provide a similar prescription for allocating interest expense for purposes of subsections (d) and (h) of section 163. In TAMRA 1988, the Congress amended subsections (d) and (h) of section 163 to conform the relevant language thereof to the relevant language of section 469 in order to achieve “consistent application of a standard for allocation of interest” among the “related provisions” of sections 163(d), 163(h), and 469. By conforming the language of subsections (d) and (h) to section 163 to the relevant language of section 469, the Congress gave a clear indication that the tracing regime it contemplated for purposes of section 469 is the allocation method that it also intended for subsections (d) and (h) of section 163. See Appendix pp. 73-74. An examination of section 1.163-8T, Temporary Income Tax Regs., supra, shows that the Secretary heeded the Congress’s suggestion. Section 1.163-8T, Temporary Income Tax Regs., supra, imposes the very tracing regime that the Congress contemplated. Sec. 1.163-8T(a)(3), Temporary Income Tax Regs., supra. In sum, the Congress suggested the means by which to allocate interest expense for purposes of section 469; thePage: Previous 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 Next
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