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Section 301 of the Tax Reform Act of 1969, Pub. L. 91-172,
83 Stat. 580, imposed a minimum tax on certain tax preference
items to be added on to a taxpayer's other tax liability. This
scheme remained in effect, with only minor changes, as the only
minimum tax formulation in the Internal Revenue Code until 1978.
See Revenue Act of 1978, Pub. L. 95-600, sec. 421(a), 92 Stat.
2871.
The Revenue Act of 1978, purported to repeal the add-on
minimum tax for individuals and replace it with a new AMT
formulation beginning in 1979. Other sources indicate, however,
that the two provisions co-existed in the Internal Revenue Code
until the add-on minimum tax was finally repealed by the Tax
Equity and Fiscal Responsibility Act of 1982 (TEFRA), Pub. L. 97-
248, sec. 201(a), 96 Stat. 411, and supplanted by an amended
alternative minimum tax. E.I. du Pont de Nemours & Co. v.
Commissioner, 102 T.C. 1, 18 n.10, affd. 41 F.3d 130 (3d Cir.
1994), affd. sub nom. Conoco, Inc. v. Commissioner, 42 F.3d 972
(5th Cir. 1995); United States v. Deckelbaum, 784 F. Supp. 1206,
1208 (D. Md. 1992). This TEFRA AMT provision remained in effect
from 1982 until its amendment by the Tax Reform Act of 1986, Pub.
L. 99-514, 100 Stat. 2085, which expanded the AMT for
individuals. See S. Rept. 99-313 (1986), 1986-3 C.B. (Vol. 3)
515, 521.
The post-1986 AMT rules, sections 55-59, were enacted to
achieve one overriding objective: to establish a floor for tax
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