[Congressional Bills 109th Congress]
[From the U.S. Government Publishing Office]
[H.R. 3180 Introduced in House (IH)]






109th CONGRESS
  1st Session
                                H. R. 3180

  To amend the Internal Revenue Code of 1986 to allow a deduction for 
           qualified attorney fees in computing minimum tax.


_______________________________________________________________________


                    IN THE HOUSE OF REPRESENTATIVES

                             June 30, 2005

   Mr. Paul introduced the following bill; which was referred to the 
                      Committee on Ways and Means

_______________________________________________________________________

                                 A BILL


 
  To amend the Internal Revenue Code of 1986 to allow a deduction for 
           qualified attorney fees in computing minimum tax.

    Be it enacted by the Senate and House of Representatives of the 
United States of America in Congress assembled,

SECTION 1. DEDUCTION ALLOWED IN COMPUTING MINIMUM TAX.

    (a) In General.--Section 212 of the Internal Revenue Code of 1986 
(relating to expenses for production of income) is amended to read as 
follows:

``SEC. 212. EXPENSES FOR PRODUCTION OF INCOME.

    ``(a) Allowance of Deduction.--In the case of an individual, there 
shall be allowed as a deduction all the ordinary and necessary expenses 
paid or incurred during the taxable year--
            ``(1) for the production or collection of income,
            ``(2) for the management, conservation, or maintenance of 
        property held for the production of income, or
            ``(3) in connection with the determination, collection, or 
        refund of any tax.
    ``(b) Qualified Attorney Fees.--For purposes of this section--
            ``(1) Allowance of deduction.--The ordinary and necessary 
        expenses paid or incurred for the production or collection of 
        income (referred to in subsection (a)(1)) include qualified 
        attorney fees.
            ``(2) Deduction allowed in computing minimum tax.--The 
        deduction under subsection (a) for qualified attorney fees 
        shall be allowed for purposes of the tax imposed by section 55.
            ``(3) Qualified attorney fees.--The term `qualified 
        attorney fees' means attorney fees and court costs paid by, or 
        on behalf of, the taxpayer in connection with any judgment or 
        settlement (whether by suit or agreement and whether as lump 
        sum or periodic payments) resulting from a civil action brought 
        by the taxpayer in a court of law.''.
    (b) Effective Date.--The amendment made by this section shall apply 
to taxable years beginning after December 31, 2004.
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