Edward A. Robinson III and Diana R. Robinson - Page 100




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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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