- 66 - residence of the taxpayer (to the extent of their fair market values) is not subject to limitation. * * * Consumer interest means interest not attributable to a trade or business (other than the trade or business of performing services as an employee) or to an activity engaged in for profit. * * * * * * * Conference Agreement The conference agreement follows the Senate amendment, with modifications and clarifications. * * * * * * * Personal interest The conference agreement follows the Senate amendment provision with respect to consumer interest (denominated personal interest under the conference agreement), with modifications and clarifications. Under the conference agreement, personal interest is not deductible. Personal interest is any interest, other than interest incurred or continued in connection with the conduct of a trade or business (other than the trade or business of performing services as a employee), investment interest, or interest taken into account in computing the taxpayer’s income or loss from passive activities for the year. Personal interest also generally includes interest on tax deficiencies. Personal interest does not include qualified residence interest of the taxpayer, nor does it include interest payable on estate tax deferred under sec. 6163 or 6166. [H. Conf. Rept. 99-841, at II-151 to II-154, supra, 1986-3 C.B. (Vol. 4) at 151-154.] In all material respects, section 511(b) as reported by the conference committee was identical to section 511(b) of H.R. 3838 as ultimately enacted, on October 22, 1986. TRA 1986 sec. 511(b), Pub. L. 99-514, 100 Stat. 2085, 2246-2248, 2963.Page: Previous 56 57 58 59 60 61 62 63 64 65 66 67 68 69 70 71 72 73 74 75 Next
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