Norwest Corporation and Subsidiaries - Page 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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