100 STAT. 2114
PUBLIC LAW 99-514—OCT. 22, 1986
"SEC. 67. 2-PERCENT FLOOR ON MISCELLANEOUS ITEMIZED DEDUCTIONS.
"(a) GENERAL RULE.—In the case of an individual, the miscellaneous itemized deductions for any taxable year shall be allowed only to the extent that the aggregate of such deductions exceeds 2 percent of adjusted gross income. "(b) MISCELLANEOUS ITEMIZED DEDUCTIONS.—For purposes of this section, the term 'miscellaneous itemized deductions' means the itemized deductions other than— "(1) the deduction under section 163 (relating to interest), "(2) the deduction under section 164 (relating to taxes), "(3) the deduction under section 165(a) for losses described in subsection (c)(3) or (d) of section 165, "(4) the deduction under section 170 (relating to charitable, etc., contributions and gifts), "(5) the deduction under section 213 (relating to medical, dental, etc., expenses), "(6) the deduction under section 217 (relating to moving expenses), "(7) any deduction allowable for impairment-related work expenses, "(8) the deduction under section 691(c) (relating to deduction for estate tax in ceise of income in respect of the decedent), "(9) any deduction allowable in connection with personal property used in a short sale, "(10) the deduction under section 1341 (relating to computation of tax where taxpayer restores substantial amount held under claim of right), "(11) the deduction under section 720t))(3) (relating to deduction where annuity payments cease before investment recovered), "(l2) the deduction under section 171 (relating to deduction for amortizable bond premium), and "(13) the deduction under section 216 (relating to deductions in connection with cooperative housing corporations). "(c) DISALLOWANCE OF INDIRECT DEDUCTION THROUGH PASS-THRU
ENTITY.—The Secretary shall prescribe regulations which prohibit the indirect deduction through pass-thru entities of amounts which are not allowable as a deduction if paid or incurred directly by an individual and which contain such reporting requirements as may be necessary to carry out the purposes of this subsection. The preceding sentence shall not apply with respect to estates, trusts, cooperatives, and real estate investment trusts. "(d) IMPAIRMENT-RELATED WORK EXPENSES.—For purposes of this section, the term 'impairment-related work expenses means expenses— "(1) of a handicapped individual (as defined in section 190(b)(3)) for attendant care services at the individual's place of employment and other expenses in connection with such place of employment which are necessary for such individual to be able to work, and "(2) with respect to which a deduction is allowable under section 162 (determined without regard to this section). "(e) DETERMINATION OF ADJUSTED GROSS INCOME IN CASE OF ESTATES AND TRUSTS.—For purposes of this section, the adjusted gross
income of an estate or trust shall be computed in the same manner as in the case of an individual, except that the deductions for osts
�
