- 7 - liability, so that a taxpayer pays some tax regardless of the tax breaks otherwise available to him under the RIT. See S. Rept. 99-313, supra, 1986-3 C.B. (Vol. 3) at 518. The AMT rules accomplish this goal by eliminating favorable treatment to certain items that are treated favorably for purposes of the RIT (tax preference items). Secs. 55(b)(2)(B), 57(a). The AMT is paid only if, and to the extent that, it exceeds the taxpayer's RIT. Sec. 55(a). The starting point in computing AMT liability is determining AMTI. AMTI is computed in the same manner as regular taxable income except that the adjustments provided in sections 56 and 58 are taken into account for AMTI, and the tax preference items set forth in section 57 are not permitted to reduce AMTI. Sec. 55(b)(2). To determine the taxable amount of AMTI, AMTI is reduced by an exemption amount, which, in the instant case, amounts to $40,000, subject to a gradual phase-out as AMTI exceeds $150,000. Sec. 55(d). The AMT rate is then applied to AMTI, as reduced by the exemption amount. Sec. 55(b). For the taxable years at issue in the instant case, the applicable AMT rate is 21 percent. The resulting tax figure is then reduced by the alternative minimum foreign tax credit (which petitioners did not have in any of the taxable years at issue) to arrive at TMT. Sec. 55(b)(1)(A). Next, RIT is compared to TMT. RIT is not reduced by any nonrefundable credits, other than the foreign tax credit and the possessions tax credit, before being compared to the TMT. Sec.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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