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Petitioners acknowledge that the constitutionality of the
alternative minimum tax was upheld in Okin v. Commissioner,
T.C. Memo. 1985-199, affd. 808 F.2d 1338 (9th Cir. 1987),
but they argue that their case "is totally different" from
Okin. We disagree.
In Okin v. Commissioner, supra, the taxpayer's
principal argument was that under a prior version of the
alternative minimum tax, viz the Revenue Act of 1978, Pub.
L. 95-600, sec. 421, 92 Stat. 2763, 2871, alternative
minimum taxable income should be computed using "average
annual adjusted gross income", a concept taken from the
income averaging provisions of sections 1301-1305. We
rejected the taxpayer's argument and pointed out that, in
defining alternative minimum taxable income, the statute
used the words "gross income" and did not refer to the
income averaging provisions or to any adjusted figure.
Okin v. Commissioner, supra. After trial, the taxpayer
made a general argument, "not supported by any specific
references to the Constitution or citations to precedent",
that section 55 is unconstitutional. Id. We rejected
that argument on the basis of cases upholding the con-
stitutionality of the so-called add-on minimum tax under
former section 56. See Wyly v. United States, 662 F.2d
397, 403-406 (5th Cir. 1981); Graff v. Commissioner, 74
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