- 48 -
section 163(h)(2)(A) does not compel this result. The relevant
legislative history, however, lends some support to this
interpretation of the statute.
The Joint Committee staff summary, which we did not consider
in Redlark v. Commissioner, supra, provides, in pertinent part,
as follows: “Interest on underpayments of tax (other than certain
deferred estate taxes) is treated as personal interest under the
provision [sec. 163(h)].” Joint Committee staff summary at 18.
Under this view, interest on underpayments of “certain deferred
estate taxes” is the only type of interest on underpayments of
tax that is excluded from the definition of personal interest.
This view supports section 1.163-9T(b)(2)(i)(A), Temporary Income
Tax Regs., supra, which includes interest paid on underpayments
of Federal income taxes within the definition of personal
interest.
We acknowledge that the Joint Committee staff summary is not
the official legislative document for the conference committee’s
decisions about TRA 1986; that distinction is accorded the
conference committee report. Joint Committee staff summary at
XIII. Further, by definition, the Joint Committee staff summary
may not be a complete or thorough statement of the conference
decisions; summaries are designed to cover concisely the main
points of the summarized topic, and they may lack specific
detail. However, the Joint Committee staff summary was provided
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