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purposes must recompute those itemized deductions for AMT
purposes without regard to the section 68 limitation. For
section 56(b)(1)(F) to apply at all, the taxpayer must have
elected to itemize deductions for regular tax purposes and had
those deductions reduced pursuant to section 68. Petitioner’s
interpretation goes well beyond the limited application of
section 56(b)(1)(F).
To interpret section 56(b)(1)(F) alone without giving full
effect to all the provisions of section 56(b) renders section
56(b)(1)(E) inoperative. Petitioner’s argument is a narrow
interpretation that overlooks section 56(b)(1)(E). By strictly
isolating section 56(b)(1)(F), petitioner is attempting to change
the meaning of the statute as a whole. The only way petitioner’s
argument would have validity would be if section 56(b) contained
a provision allowing the taxpayer to pick and choose which
adjustments were most favorable to his particular tax situation
or a provision allowing for adjustments for itemized deductions
that were not deducted for regular tax purposes because the
standard deduction was claimed. However, no such provisions
exist in the Code. When read as a whole, section 56(b) requires
the taxpayer to make adjustments for AMT purposes in a manner
consistent with decisions made for regular tax purposes.
Accordingly, petitioner’s argument that section 56(b)(1)(F)
allows him to compute AMTI using the full value of his otherwise
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