Edward A. Robinson III and Diana R. Robinson - Page 92




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               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.                     






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