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The AMT would "ensure that high-income individuals and
corporations pay at least a minimum rate of tax on their tax
preferences". S. Rept. 94-938 (1976), 1976-3 C.B. (Vol. 3) 49,
147. Such a goal is a legitimate governmental end. Okin v.
Commissioner, supra at 1342. Tax Reform Act of 1976, Pub. L. 94-
455, sec. 301(c)(1)(A), 90 Stat. 1520, designated as a tax
preference a portion of an individual's "excess itemized
deductions", including miscellaneous itemized deductions. See
former secs. 57(a)(1), (b).2 This provision was designed "to
prevent high-income people from using itemized deductions to
avoid all tax liability." S. Rept. 94-938, supra, 1976-3 C.B.
(Vol. 3) at 150; see H. Rept. 94-658 (1975), 1976-3 C.B. (Vol. 2)
695, 823.
Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA),
Pub. L. 97-248, sec. 201(a), 96 Stat. 411, introduced the concept
of AMTI, calculated by, among other adjustments, reducing
adjusted gross income by "alternative tax itemized deductions".
Sec. 55(b), as amended by TEFRA sec. 201(a), Pub. L. 97-248, 96
Stat. 411. Absent entirely from the alternative tax itemized
deductions were miscellaneous itemized deductions. Sec. 55(e),
as amended by TEFRA sec. 201(a), Pub. L. 97-248, 96 Stat. 411.
In making revisions to the AMT, Congress had "one overriding
2 Currently miscellaneous itemized deductions are not classified
as tax preferences; rather, sec. 56(b) imposes "Adjustments
Applicable to Individuals", including the disallowance of these
deductions.
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