Roy E. and Linda Day - Page 6

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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            until the add-on minimum tax was finally repealed by the Tax                                 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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