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tax statute may be entitled to respect as a document that is
prepared in connection with the legislative process by
individuals who are intimately involved in that process, we shall
not hesitate to disregard the expressions set forth therein
where, as here, those expressions are barren of corroboration in
the legislative history. Zinniel v. Commissioner, 89 T.C. 357,
367 (1987), affd. 883 F.2d 1350 (7th Cir. 1989); see also
Estate of Wallace v. Commissioner, 965 F.2d 1038, 1050-1051 n.15
(11th Cir. 1992), affg. 95 T.C. 525 (1990).
Even if we were to follow the lead of the parties and rely
on the General Explanation of the 1986 Act for an expression of
legislative intent as to the current AMT regime, we would still
not reach their proffered conclusion that Congress intended that
the regular tax and AMT regimes operate as parallel systems. In
fact, the primary provision of the General Explanation of the
1986 Act that the parties quote in support of their contention
that the systems are “parallel” does not even use that word.
Moreover, that provision actually contradicts the parties’
10(...continued)
the Senate and 5 from the House of Representatives. 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) II. The General Explanation of the 1986 Act was
prepared by the Staff of Joint Committee, in consultation with
the staffs of the House Ways and Means Committee and the Senate
Finance Committee. Letter from David H. Brockway, Chief of
Staff, to the Hon. Dan Rostenkowski, Chairman, and the Hon. Lloyd
Bentsen, Vice-Chairman. Id. at XVII.
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