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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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