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claimed on his return by virtue of the TMT limitation of section
38(c)(1)(A).
Discussion
The Internal Revenue Code imposes upon taxpayers an
alternative minimum tax (AMT) in addition to all other taxes
imposed by subtitle A. See sec. 55(a). The AMT is imposed upon
a taxpayer’s AMTI, which is an income base broader than the usual
base of taxable income applicable to Federal income taxes in
general. See H. Conf. Rept. 99-841 (Vol. II), at II-249
(individual AMT), II-263 (corporate AMT) (1986), 1986-3 C.B.
(Vol. 4) 250, 264. Congress established AMTI as a broad base of
income in order to tax taxpayers more closely on their economic
income, intending for all taxpayers to pay their fair share of
the overall Federal income tax burden. See S. Rept. 99-313, at
518-519 (1986), 1986-3 C.B. (Vol. 3) 518-519; H. Rept. 99-426,
at 305-306 (1985), 1986-3 C.B. (Vol. 2) 305-306. Congress
required that corporations be taxed at a single AMT rate and that
individuals be taxed under a progressive AMT regime with two
rates. The highest AMT rate applicable to a taxpayer is lower
than the taxpayer’s maximum rate of taxation under the regular
tax regime, and a taxpayer must pay AMT when the taxpayer’s AMT
liability is greater than the taxpayer’s regular tax liability.
The instant case focuses on the tax base upon which AMTI is
calculated. Specifically, we pass for the first time on the
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