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addition, personal interest does not include interest of an
S corporation which is attributable to an underpayment of
income tax from a year in which the corporation was a C
corporation or from the underpayment of the taxes imposed by
sec. 1374 or 1375. Nor does personal interest include
interest on an underpayment of income tax of a corporation
payable by a shareholder by reason of transferee liability
(under sec. 6901).
(7) TAMRA 1988
On June 10, 1987, the Technical Corrections Act of 1987 was
introduced in the House of Representatives (H.R. 2636) by Ways
and Means Committee Chairman Rostenkowski and Congressman Duncan,
and in the Senate (S. 1350) by Finance Committee Chairman Bentsen
and Senator Packwood. Section 105(c) of the bills provided as
follows:
SEC. 105. AMENDMENTS RELATED TO TITLE V OF THE REFORM ACT.
[The Tax Reform Act of 1986, see sec. 1(b)(2)
of the bills.]
* * * * * * *
(c) Amendments Related to Section 511 of the Reform
Act.--
(1) Subparagraph (A) of section 163(d)(3) of the
1986 Code (defining investment interest) is amended by
striking out “incurred or continued to purchase or
carry” and inserting in lieu thereof “properly
allocable to”.
* * * * * * *
(4) Subparagraph (A) of section 163(h)(2) of the
1986 Code is amended by striking out “incurred or
continued in connection with the conduct of” and
inserting in lieu thereof “properly allocable to”.
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