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objective: no taxpayer with substantial economic income should be
able to avoid all tax liability by using exclusions, deductions
and credits. * * * The only deductions allowed, other than costs
of producing [investment] income, are for important personal or
unavoidable expenditures * * * or for charitable contributions".
S. Rept. 97-494, at 108 (1982).
It is apparent that any difference in the AMT treatment of
the expenses of employees and the self-employed is rationally
related to Congress' goal of implementing a broad based tax
system. As the 1944 legislative history indicates, trade or
business expenses of the self-employed are deductible "above the
line" to achieve parity in treatment with other taxpayers. The
rationale behind this dichotomy applies with equal force to the
AMT, as the distinction levels the field for employees and the
self-employed for the application of the AMT. Neither class of
taxpayer may deduct miscellaneous itemized deductions in
calculating AMT.
Petitioner contends, however, that he is not a high-income
taxpayer. To a great extent what constitutes a "high-income"
taxpayer or a taxpayer having "substantial economic income" lies
within the eyes of the beholder. Nonetheless, Congress, in
addition to other adjustments, provided a so-called exemption
amount of $20,000, for married taxpayers filing separate returns,
in computing the amount of the AMT. Sec. 55(d). This provides
the statutory parameter, and petitioner falls within that
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