-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 * * *Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011