Roy E. and Linda Day - Page 14

                                                - 14 -                                                   
            which the item is taken into account or for any other taxable                                
            year." (Emphasis added.)  In the instant case, however,                                      
            petitioners may obtain a tax benefit from their tax preference                               
            items indirectly, through "liberated" section 29 credits that can                            
            be applied against RIT in future taxable years pursuant to                                   
            section 53.                                                                                  
                  Petitioners argue that the fact that they may, at some                                 
            future time, indirectly derive a tax benefit from the tax                                    
            preference items via the freed-up section 29 credits is mooted by                            
            First Chicago Corp. v. Commissioner, 842 F.2d 180 (7th Cir.                                  
                  In First Chicago Corp., the taxpayer had no regular tax                                
            liability for 1980 and 1981 in large part due to a plethora of                               
            foreign tax credits.  Id. at 180-181.  The credits were                                      
            sufficient to offset in full the tax liability that would have                               
            resulted if the taxpayer's regular income had not also been                                  
            reduced by preference items.  Id.  Thus, the taxpayer received no                            
            current tax benefit from the preferences.  Id. at 181.  Moreover,                            
            the excess credits liberated by the preferences had not yet                                  
            expired unused.  Id.                                                                         
                  Respondent argued that the add-on minimum tax should                                   
            nevertheless be imposed for 1980 and 1981 because of the                                     
            potential for tax reduction in subsequent years.  However, this                              
            Court, as well as the Court of Appeals for the Seventh Circuit,                              
            was concerned that if the taxpayer paid tax on a preference item                             

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