Edward A. Robinson III and Diana R. Robinson - Page 83




                                        - 57 -                                         
          B. Interest Deduction Limitations (Sec. 402 of the bill                      
          and sec. 163(d) of the Code)                                                 
          Present Law                                                                  
               In general                                                              
                         *     *     *     *     *     *     *                         
                    Under present law, no limitation is imposed under                  
               section 163(d) on the deductibility of either interest                  
               on indebtedness incurred to purchase or carry                           
               consumption goods, (i.e., personal (consumer)                           
               interest), or interest on indebtedness incurred in                      
               connection with the taxpayer’s trade or business. [H.                   
               Rept. 99-426 at 296 supra, 1986-3 C.B. (Vol. 2) at                      
               296.]                                                                   
                         *     *     *     *     *     *     *                         
                               Explanation of Provision                                
               In general                                                              
                    The bill expands the scope of the interest                         
               limitation, and alters the calculation of the amount of                 
               the limitation.  Under the bill, all nonbusiness                        
               interest is subject to the limitation on deductibility,                 
               including consumer interest and certain interest that                   
               is not treated as investment interest subject to                        
               limitation under present law.  Nonbusiness interest                     
               subject to the limitation under the bill does not                       
               include interest on debt secured by the taxpayer’s                      
               principal residence (to the extent of its fair market                   
               value), and interest on debt secured by a second                        
               residence of the taxpayer (to the extent of its fair                    
               market value).  Interest expense that is paid or                        
               incurred in carrying on a trade or business (except for                 
               interest attributable to certain limited business                       
               interests not involving low-income housing), is not                     
               subject to the interest deduction limitation under the                  
               bill. [Id. at 298.]                                                     
                         *     *     *     *     *     *     *                         









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