- 49 - 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 thePage: Previous 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 Next
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