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to the Members of the House and Senate for their reference before
Congress enacted TRA 1986, and consequently it is part of the
history of the legislation. See, e.g., Newborn v. Commissioner,
94 T.C. 610, 620, 623 (1990). Thus, before the enactment of TRA
1986, the Members of Congress had before them an interpretation
of section 163(h) that included within the definition of
“personal interest” interest on underpayments of income tax.
Although not as clearly expressed as in the Joint Committee
staff summary, the relevant portions of the Joint Statement of
Managers portion of the conference committee report may be read
to echo the views expressed in the Joint Committee staff summary.
The relevant portions of the Joint Statement of Managers portion
of the conference committee report provide that “Personal
interest also generally includes interest on tax deficiencies”
and that “personal interest does not include * * * interest
payable on estate tax deferred under sec. 6163 or 6166.” H.
Conf. Rept. 99-841, at II-154, supra, 1986-3 C.B. (Vol. 4) at
154. These portions of the Joint Statement of Managers Portion
of the conference committee report may be read to support a view
that interest on all tax underpayments other than interest in
respect of estate tax deferred under either section 6163 or 6166
is to be treated as personal interest.
Although the Joint Statement of Managers portion of the
conference committee report does not speak as clearly to the
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