Charles C. Allen, III and Barbara N. Allen, et al. - Page 13




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          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).                                      





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