Edward A. Robinson III and Diana R. Robinson - Page 86




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               trade or business is also not subject to the section                    
               163(d) limitation under present law.                                    
                                 Reasons for Change                                    
                         *     *     *     *     *     *     *                         
               Nonbusiness (consumer) interest                                         
                         *     *     *     *     *     *     *                         
                    Although the committee believes it would not be                    
               advisable to subject to income tax imputed rental                       
               income with respect to consumer durables owned by the                   
               taxpayer, it does believe that it is appropriate and                    
               practical to address situations where consumer                          
               expenditures are financed by borrowing.  By phasing out                 
               the present deductibility of consumer interest, the                     
               committee believes that it has eliminated from the                      
               present tax law a significant disincentive to saving.                   
                         *     *     *     *     *     *     *                         
          Explanation of Provisions                                                    
               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.  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 is not subject to the interest deduction                       
               limitation under the bill (except for interest                          
               attributable to certain limited business interests).                    
                    In general, under the bill, consumer interest is                   
               not deductible, and the deduction for investment                        
               interest is limited to investment income for the year                   






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