Edward A. Robinson III and Diana R. Robinson - Page 85




                                        - 59 -                                         
                    “(h) Disallowance of Deduction for Consumer                        
               Interest.--                                                             
                         “(1) In general.--In the case of a taxpayer other             
                    than a corporation, no deduction shall be allowed under            
                    this chapter for consumer interest paid or accrued                 
                    during the taxable year.                                           
                         “(2) Consumer interest.--For purposes of this                 
                    subsection--                                                       
                              “(A) In general.--The term ‘consumer                     
                         interest’ means any interest allowable as a                   
                         deduction under this chapter other than interest              
                         paid or accrued on indebtedness incurred or                   
                         continued in connection with--                                
                                   “(i) the conduct of a trade or business             
                              (other than the trade or business of                     
                              performing services as an employee), or                  
                                   “(ii) an activity described in section              
                              212.                                                     
                              “(B) Exception for qualified residence                   
                         interest.--The term ‘consumer interest’ shall not             
                         include any qualified residence interest.[”]                  
               The Senate Finance Committee report, provides, in pertinent             
          part, as follows (S. Rept. 99-313, at 802-806 (1986), 1986-3 C.B.            
          (Vol. 3) 1, 802-806):                                                        
                    G. Interest Deduction Limitations (sec. 1421 of the                
                    bill and secs. 163(d) and (h) of the Code)                         
               Present Law                                                             
                         *     *     *     *     *     *     *                         
               Other interest                                                          
                    Under present law, no limitation is imposed under                  
               section 163(d) on the deductibility of interest on                      
               indebtedness incurred for other purposes, e.g. to                       
               purchase or carry consumption goods.  Interest on                       
               indebtedness incurred in connection with the taxpayer’s                 





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