Edward A. Robinson III and Diana R. Robinson - Page 71




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               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; the                   





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