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position by stating “For most purposes, the tax base * * * is
determined as though the alternative minimum tax were a separate
and independent income tax system.” General Explanation of the
1986 Act, supra at 438 (emphasis added). To our minds, the
phrase “For most purposes” means that even the Joint Committee
recognized that the regular tax and AMT systems were not parallel
systems for all purposes. The same is true as to the use of the
term “as though”, rather than a term such as “by virtue of the
fact that”. As to the Joint Committee’s use of the term
“separate and independent”, we find no statement in the General
Explanation of the 1986 Act to the effect that the two regimes
are separate and independent for all purposes. And even if we
did, the mere fact that two systems are “separate and
independent” does not make them “parallel”.
The General Explanation of the 1986 Act uses the word
“parallel” only twice in its discussion of AMT. First, as to the
treatment of AMT NOLs, the General Explanation of the 1986 Act
states:
In light of the parallel nature of the regular tax
and minimum tax systems, any limitations applying for
regular tax purposes to the use by a consolidated group
of NOLs or current year losses (e.g., section 1503)
apply for minimum tax purposes as well. Moreover, an
election under section 172(b)(3)(C) to relinquish the
carryback period applies for both regular tax and
minimum purposes. [General Explanation of the 1986
Act, supra at 470.]
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