Edward A. Robinson III and Diana R. Robinson - Page 75




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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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