Charles C. Allen, III and Barbara N. Allen, et al. - Page 17




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          Alternative Minimum Tax–-Corporations; Form 6251 (individuals).               
          Because section 280C is a wage-expense limitation that enters                 
          into the computation of taxable income for purposes of section                
          63(a), and section 280C(a) is not referenced in part VI, we                   
          conclude naturally that the limitation is reflected in the                    
          calculation of AMTI.                                                          
               Petitioners assert in their brief that the legislative                   
          history underlying AMT “makes clear” that the AMT regime is a                 
          “separate and independent tax system that operates in parallel                
          with the RT [regular tax] system and requires separate                        
          calculations of a taxpayer’s” taxable income for regular tax                  
          purposes and AMTI.  Petitioners conclude that, notwithstanding                
          the fact that section 280C(a) is not referenced in part VI,                   
          section 280C(a) is inapplicable in the AMT regime because the TJC             
          is also inapplicable there.  Respondent does not disagree with                
          the parallel tax regime rationale advanced by petitioners.                    
          Respondent invites the Court to hold that the systems are                     
          “parallel” in the sense that a taxpayer who has calculated                    
          taxable income must start from scratch in a separate computation              
          of AMTI.  Both respondent and petitioners rely extensively upon               
          the Staff of Joint Comm. on Taxation, General Explanation of the              
          Tax Reform Act of 1986 (J. Comm. Print 1987) (General Explanation             
          of the 1986 Act), in arguing that the legislative history under               








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