DISC has undergone almost a dozen changes from the time it was first contemplated until it was enacted as part of the Revenue Act of 1971. DISC had been conceived during 1969 but not included in the Tax Reform Act of 1969. Early in 1970, there was a Treasury proposal on DISC followed by a draft bill, and later proposed legislation before the House Committee on Ways & Means. DISC was not enacted in 1970, and when it was reintroduced by the Treasury in 1971 there were significant modifications.
Later, the House Ways & Means Committee, the Senate Finance the ,full Senate, and the Joint Conference Committee made changes in DISC.
These numerous changes in DISC
have presented problems of internal inconsistency, correlation
with the Committee Reports, and technical features. This has substantially
increased the need for regulations. Qualification requirements
for DISC is one aspect of DISC where these problems arise. This
is the scope of our present analysis.
