Charles C. Allen, III and Barbara N. Allen, et al. - Page 7




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          claimed on his return by virtue of the TMT limitation of section              
          38(c)(1)(A).                                                                  
                                      Discussion                                        
               The Internal Revenue Code imposes upon taxpayers an                      
          alternative minimum tax (AMT) in addition to all other taxes                  
          imposed by subtitle A.  See sec. 55(a).  The AMT is imposed upon              
          a taxpayer’s AMTI, which is an income base broader than the usual             
          base of taxable income applicable to Federal income taxes in                  
          general.  See H. Conf. Rept. 99-841 (Vol. II), at II-249                      
          (individual AMT), II-263 (corporate AMT) (1986), 1986-3 C.B.                  
          (Vol. 4) 250, 264.  Congress established AMTI as a broad base of              
          income in order to tax taxpayers more closely on their economic               
          income, intending for all taxpayers to pay their fair share of                
          the overall Federal income tax burden.  See S. Rept. 99-313, at               
          518-519 (1986), 1986-3 C.B. (Vol. 3) 518-519; H. Rept. 99-426,                
          at 305-306 (1985), 1986-3 C.B. (Vol. 2) 305-306.  Congress                    
          required that corporations be taxed at a single AMT rate and that             
          individuals be taxed under a progressive AMT regime with two                  
          rates.  The highest AMT rate applicable to a taxpayer is lower                
          than the taxpayer’s maximum rate of taxation under the regular                
          tax regime, and a taxpayer must pay AMT when the taxpayer’s AMT               
          liability is greater than the taxpayer’s regular tax liability.               
               The instant case focuses on the tax base upon which AMTI is              
          calculated.  Specifically, we pass for the first time on the                  






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