- 16 - The District Court in Deckelbaum expressly declined to extend the holding of First Chicago Corp. to cases involving the AMT. United States v. Deckelbaum, 784 F. Supp. at 1208. The issue was whether the taxpayers could adjust certain tax preference items downward to determine the amount of AMT they owed for 1985 under section 58(h). The taxpayers' revised computation of tax, although consonant with the taxpayers' approach in First Chicago Corp., was rejected as directly contrary to the stated goal of the AMT. Id. In Deckelbaum, because the taxpayer could not avoid AMT even in the absence of any preferences, and because nonrefundable credits could not be used to reduce AMT, the court held that a reduction of AMT under then-section 58(h) because of excess nonrefundable credits was not warranted. Id. at 1209. In so holding, Deckelbaum clarified the important distinction in the methods by which the add-on minimum tax and the AMT are calculated. Id. at 1208. The add-on minimum tax was computed on a tax base consisting of the sum of a taxpayer's tax preferences less an applicable minimum tax deduction. The minimum tax was then added to the taxpayer's RIT in order to determine his total income tax liability. Thus, a taxpayer who reported items of tax preference but who, irrespective of such items, would have owed no tax because of the availability of credits, subjected himself to tax liability under the add-on tax provisions solely by virtue of the fact that he reported the taxPage: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Next
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