- 13 - apply in the case of AMTI. Nor do we read any of the provisions underlying AMT that would lead us to that result.5 The heart of AMT is section 55. That section provides: SEC. 55. ALTERNATIVE MINIMUM TAX IMPOSED. (a) General Rule.--There is hereby imposed (in addition to any other tax imposed by this subtitle) a tax equal to the excess (if any) of-- (1) the tentative minimum tax for the taxable year, over (2) the regular tax for the taxable year. (b) Tentative minimum tax.--For purposes of this part–- (1) Amount of Tentative Tax. (A) Noncorporate taxpayers. (i) In general.--In the case of a taxpayer other than a corporation, the tentative minimum tax for the taxable year is the sum of-- (I) 26 percent of so much of the taxable excess as does not exceed $175,000, plus 5 Although respondent concedes that no petitioner is liable for AMT, we must address the AMT provisions in order to compute each petitioner’s TMT. See sec. 38(c) (in the computation of a taxpayer’s regular tax liability, the application of the TJC may be limited by the taxpayer’s TMT). The calculation of a taxpayer’s TMT is generally a three-step process in which: (1) The taxpayer’s AMTI is reduced by an exemption amount, (2) the reduced amount is multiplied by the AMT rate, and (3) the resulting tax figure is reduced by the alternative minimum foreign tax credit. Sec. 55(b)(1), (d).Page: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
Last modified: May 25, 2011