Norwest Corporation and Subsidiaries - Page 3

            respondent recomputed petitioner's regular tax deduction and                              
            minimum tax.  These recomputations resulted in deficiencies in                            
            petitioner's income taxes for 1983, 1984, and 1986.                                       
            Statutory Minimum Tax Provisions                                                          
                  Section 56(a) imposes a corporate minimum tax of 15 percent on                      
            "items of tax preference"1 to the extent the sum of such items                            
            exceeds the greater of $10,000 or the regular tax deduction                               
            (defined by section 56(c)).  Section 56 provides in pertinent part:                       
                        (a) GENERAL RULE.--In addition to the other taxes                             
                  imposed by this chapter, there is hereby imposed for each                           
                  taxable year, with respect to the income of every                                   
                  corporation, a tax equal to 15 percent of the amount by                             
                  which the sum of the items of tax preference exceeds the                            
                  greater of--                                                                        
                           (1) $10,000, or                                                            
                           (2) the regular tax deduction for the taxable                              
                        year (as determined under subsection (c)).                                    
                  *    *    *    *    *    *    *                                                     
                        (c) REGULAR TAX DEDUCTION DEFINED.--For purposes of                           
                  this section, the term "regular tax deduction" means an                             
                  amount equal to the taxes imposed by this chapter for the                           
                  taxable year (computed without regard to this part * * *                            
                  Petitioner contends that its minimum tax computation                                
            (including the calculation of its regular tax deduction) should be                        
            done on a separate return basis.  To support this position,                               
            petitioner relies on that portion of section 56(a) that imposes a                         
            minimum tax "with respect to the income of every corporation".  On                        

                  1     Items of tax preference are set forth in sec. 57(a) and                       
            include benefits such as accelerated depreciation and the tax                             
            reduction for capital gains.                                                              

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