MM. ON TAXATION, 98TH CONG., GENERAL EXPLANATION OF TEE REVZIUE PROVISIONS OF THE DEFICIT REDUCTION ACT OF 1984, at 463 (Comm. Print 1984); see also H.R. REP. No. 98-432, pt. 1, at 222. 96 See H.R. REP. No. 98-861, at 188-189, 967 (1984) (Conf. Rep.) (setting forth text of § 7701(bX3) and describing the