William G. and Vivian Loomis - Page 7

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          Thus, respondent reasoned that the sales pursuant to the con-               
          tracts constitute dispositions of property described in section             
          1221(1). Therefore, respondent concluded, under section 56(a)(6),           
          for AMT purposes, petitioners must determine income from the                
          grain sales without regard to the installment method.  Accord-              
          ingly, respondent argued that the gain from the contracts must be           
          included in petitioners' income in 1991 for purposes of calcu-              
          lating their AMTI.                                                          
               However, on August 5, 1997, the President signed the                   
          Taxpayer Relief Act of 1997, Pub. L. 105-34, 111 Stat. 788 (the             
          Act).  Section 403 of the Act provides:                                     
               SEC. 403. Minimum Tax Not to Apply to Farmers' Install-                
                    ment Sales.                                                       
                         (a) In general.--Subsection (a) of section 56                
                    is amended by striking paragraph (6) (relating to                 
                    treatment of installment sales) * * *.                            
                         (b) Effective dates.--                                       
                                   (1) In general.--The amendment made                
                              by this section shall apply to disposi-                 
                              tions in taxable years beginning after                  
                              December 31, 1987.                                      
          This provision removes section 56(a)(6) from the Internal Revenue           
          Code.  Further, the amendment is made applicable to dispositions            
          after December 31, 1987.  Thus, this provision covers the sales             
          made in 1991 under the contracts, and petitioners are therefore             
          permitted to use the installment method in calculating their AMTI           
          for 1991.  Accordingly, we conclude that income from the con-               

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