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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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