-8-
calculating the amount of their "regular tax" for alternative
minimum tax purposes. We stated:
Petitioners would have us read * * * [the statute] as
defining regular tax as the tax computed under section 1
regardless of the tax actually imposed thereunder. This
we cannot do. The statutory language is "taxes imposed."
Id. at 935.
Petitioner distinguishes its situation from that involved in
Sparrow by claiming: (1) In Sparrow, two different rate schedules
were involved, whereas in this case, there is only one, and (2)
Sparrow did not involve a consolidated group of corporate
taxpayers. We believe these differences are of no consequence.
The legislative history of the minimum tax also indicates that
the regular tax refers to the income tax actually imposed and paid:
During the last few days I have heard many
conversations about what is regarded as inequity
contained in the minimum tax provisions of the bill. For
one thing, it is said that in the case of a taxpayer not
paying any tax under present law, to put a tax of only 5
percent on the amount of his tax preference is terribly
low. For another thing, it is said that there are many
taxpayers who are paying a substantial amount of tax, but
under the bill they would have 5 percent of their tax
preferences added on top of their substantial tax bill.
My amendment seeks to get at these two inequities in
this way: First, it provides that those people who are
paying taxes can subtract from their tax preferences the
amount of their tax. That gives those who are paying
some tax a break. It gives those who are paying little
or no tax very little break or none at all.
* * * * * * *
My amendment does equity. It makes sure that those
who are not paying any taxes at all will have to pay at
least 10 percent of their tax preferences * * *
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