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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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