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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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