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The Court, accordingly, sustains respondent on the income-
averaging issue.
The second issue is the alternative minimum tax under
section 55. Section 55(a) imposes a tax equal to the excess of
(1) the tentative minimum tax for the taxable year, over (2) the
regular tax for the taxable year.
Petitioner argues that, if a taxpayer elects income
averaging, that method of computation of the tax is exclusive and
trumps the alternative minimum tax under section 55. The Court
does not agree with that argument. In the conference committee
report to the Taxpayer Relief Act of 1997, Pub. L. 105-34, sec.
933(a), 111 Stat. 881 (enacting section 1301), the conferees
stated: "the provision [sec. 1301] does not apply for purposes
of the alternative minimum tax under section 55." H. Conf. Rept.
105-220 at 508 (1997), 1997-4 C.B. (Vol. 2) 1457, 1978. The
proposed and final regulations to section 1301 include this same
provision. The preamble to the final regulations states "There
is no exception in the Code provisions relating to the
alternative minimum tax that would permit the minimum tax to be
computed without regard to the effect of farm income averaging".
T.D. 8972, 2002-1 C.B. 443, 446. This statement of the law is
consistent with the former version of section 1301 and a
comparable provision imposing a minimum tax on tax preference
income under section 56 of the Tax Reform Act of 1969. In Riley
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