Charles C. Allen, III and Barbara N. Allen, et al. - Page 15




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                               (A) determined with the                                  
                         adjustments provided in section 56                             
                         and section 58, and                                            
                               (B) increased by the amount of                           
                         the items of tax preference                                    
                         described in section 57.                                       
                    If a taxpayer is subject to the regular tax,                        
                    such taxpayer shall be subject to the tax                           
                    imposed by this section (and, if the regular                        
                    tax is determined by reference to an amount                         
                    other than taxable income, such amount shall                        
                    be treated as the taxable income of such                            
                    taxpayer for purposes of the preceding                              
                    sentence).                                                          
               From this text, we understand explicitly that the base of                
          AMTI is “taxable income”, and that this base may be affected by               
          the items described in sections 56, 57, and 58.  Sec. 55(b)(2).               
          See generally section 59, which, although not specifically                    
          mentioned in section 55, provides definitions and special rules               
          that apply in the setting of AMT.  As to the meaning of the term              
          “taxable income”, Congress has provided unambiguously and with                
          sweeping breadth that “for purposes of this subtitle, the term                
          ‘taxable income’ means gross income [see sec. 61(a) for the                   
          applicable meaning of the term “gross income”6] minus the                     
          deductions allowed by this chapter (other than the standard                   




               6 Whereas sec. 61(a) provides that the meaning of the term               
          “gross income” as set forth therein does not apply “where                     
          otherwise provided in this subtitle”, we are unaware of any                   
          provision in the subtitle that would make the sec. 61(a)                      
          definition inapplicable to sec. 63(a).                                        





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