- 7 - 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-Page: Previous 1 2 3 4 5 6 7 8 Next
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