Charles C. Allen, III and Barbara N. Allen, et al. - Page 16




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          deduction).”7  Sec. 63(a) (emphasis added).  We conclude on the               
          basis of our plain reading of the unambiguous text of sections 55             
          and 63(a) that a computation of AMTI requires that a taxpayer                 
          first compute its taxable income and then alter that amount (by               
          way of an adjustment or an increase) to reflect the items                     
          described in the remainder of pt. VI, subch. A, ch. 1, subtit. A              
          (part VI).8  In fact, notwithstanding respondent’s invitation to              
          the Court to conclude that AMTI is calculated de novo, and                    
          without regard to any calculation made for regular tax purposes,              
          our conclusion is on all fours with the manner in which                       
          respondent requires taxpayers to report their calculations of                 
          AMTI for Federal income tax purposes.  See, e.g., Form 4626,                  


               7 Congress provided the sole exception to this rule in sec.              
          63(b).  See sec. 63(a).  Section 63(b) provides:                              
                    (b) Individuals Who Do Not Itemize Their                            
               Deductions.--In the case of an individual who does not                   
               elect to itemize his deductions for the taxable year,                    
               for purposes of this subtitle, the term “taxable                         
               income” means adjusted gross income, minus--                             
                         (1) the standard deduction, and                                
                         (2) the deduction for personal                                 
                    exemptions provided in section 151.                                 
               8 Part VI includes five sections, numbered and titled as                 
          follows:                                                                      
               SEC. 55.  Alternative Minimum Tax Imposed;                               
               SEC. 56.  Adjustments in Computing Alternative Minimum                   
               Taxable Income;                                                          
               SEC. 57.  Items of Tax Preference;                                       
               SEC. 58.  Denial of Certain Losses; and                                  
               SEC. 59.  Other Definitions and Special Rules.                           





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