Charles C. Allen, III and Barbara N. Allen, et al. - Page 11




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               credit is the sum of the following credits determined                    
               for the taxable year:                                                    
                         *     *    *    *    *    *    *                               
                         (2) the targeted jobs credit determined                        
                    under section 51(a);                                                
                         *     *    *    *    *    *    *                               
                    (c)  Limitation Based on Amount of Tax.--                           
                         (1) In general.--The credit allowed                            
                    under subsection (a) for any taxable year                           
                    shall not exceed the excess (if any) of the                         
                    taxpayer’s net income tax over the greater                          
                    of--                                                                
                               (A) the tentative minimum tax                            
                         for the taxable year, or                                       
                               (B) 25 percent of so much of                             
                         the taxpayer’s net regular tax                                 
                         liability as exceeds $25,000.                                  
                    For purposes of the preceding sentence, the                         
                    term “net income tax” means the sum of the                          
                    regular tax liability and the tax imposed by                        
                    section 55, reduced by the credits allowable                        
                    under subparts A and B of this part, and the                        
                    term “net regular tax liability” means the                          
                    regular tax liability reduced by the sum of                         
                    the credits allowable under subparts A and B                        
                    of this part.                                                       
               For purposes of section 38(b)(2), the TJC generally entitles             
          a taxpayer such as Foods (and, by virtue of the passthrough                   
          nature of Foods, each petitioner) to a credit equal to a                      
          percentage of the salaries or wages (collectively, wages) which               
          it incurs in employing individuals described in one or more of                
          the targeted groups enumerated in section 51(d)(1).  If the                   
          taxpayer cannot use the full amount of a TJC on account of the                





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