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taxpayers from aggregating deductions to the point where they pay
either no tax or a "shockingly low" tax. First Chicago Corp. v.
Commissioner, 842 F.2d 180, 181 (7th Cir. 1988), affg. 88 T.C.
663 (1987).
The post-1986 AMT rules, codified as sections 55 through 59,
were enacted to achieve one overriding objective: To establish a
floor for tax liability, so that a taxpayer pays some tax
regardless of the tax benefits available to him under the regular
income tax (RIT). See S. Rept. 99-313 (1986), 1986-3 C.B. (Vol.
3) 515, 518. The AMT is paid only if, and to the extent that, it
exceeds the taxpayer's RIT. Sec. 55(a). Computing AMT liability
begins with determining alternative minimum taxable income
(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 so-called tax preference
items set forth in section 57 are not permitted to reduce AMTI.
Sec. 55(b)(2).
Section 56(b) provides as follows:
(b) Adjustments Applicable to Individuals.--In
determining the amount of the alternative minimum
taxable income of any taxpayer (other than a
corporation), the following treatment shall apply (in
lieu of the treatment applicable for purposes of
computing the regular tax):
(1) Limitations on deductions.--
(A) In general.--No deduction shall be
allowed--
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