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for investment. This change results in consistency in
the language of the provisions allocating interest
expense to the category of investment interest, and
permits consistent application of a standard for
allocation of interest. This change is not intended to
suggest that the adoption of any particular method of
allocation is required, but rather to give Treasury the
ability to devise allocation rules as simple as
possible consistent with the objectives of the
provision. The committee believes that the Treasury
should consider rules relating to the securing of
property to mitigate some of the complexities of
tracing where simplicity is desirable, so that, for
example, any interest on a loan secured by personal use
property could be considered personal interest, and any
interest on a loan secured by investment assets could
be considered investment interest. [H. Rept. 100-391,
at 1170 (1987); emphasis added.]
On December 4, 1987, Senate Budget Committee Chairman Chiles
reported S. 1920 to the Senate; part II of subtitle B of title IV
of S. 1920 as reported relates to technical amendments to TRA
1986. Paragraphs (1) and (4) of section 4665(c) of S. 1920 as
reported are identical to the language of paragraphs (1) and (4)
of section 105(c) of S. 1350 as introduced, set forth supra. The
paragraph of the document explaining the bill’s (S. 1920)
amendment to the definition of “investment interest” as reported,
except for two typographical errors, is identical to the
corresponding paragraph of the House report, set forth supra.
Reconciliation Submissions of the Instructed Committees Pursuant
to the Concurrent Resolution on the Budget for Fiscal Year 1988
(H. Con. Res. 93, Rept. 100-76), Senate Budget Committee, 100th
Cong., 1st Sess. at 272. The paragraph of the document
explaining the bill’s (S. 1920) amendment to the definition of
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