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percentage of wages that could qualify for the new jobs credit,
Congress believed that some employers might want to pay an
employee not needed for work simply to avail itself of the
credit. Such a case could occur, for example, where the combined
tax benefit from both the full deduction and credit exceeded the
cost of the wages; e.g., where an employer subject to a 70-
percent marginal tax rate received a 50-percent new jobs credit
for qualifying wages. Congress enacted section 280C to thwart
this possibility. S. Rept. 95-66, at 68-69 (1977), 1977-1 C.B.
469, 488-489. One year later, Congress amended the provisions
relating to the new jobs credit to replace it with the TJC. The
legislative history accompanying this amendment does not
elaborate as to the reason for a wage-expense limitation in the
case of the TJC but states simply that such a reduction is
required. H. Conf. Rept. 95-1800, at 231–232 (1978), 1978-3 C.B.
(Vol. 1) 565-566; S. Rept. 95-1263, at 127 (1978), 1978-3 C.B.
(Vol. 1) 315, 425.
As to the provisions on AMT, those provisions find their
roots in the Tax Reform Act of 1969 (the 1969 Act), Pub. L.
91-172, 83 Stat. 487, where Congress set forth rules for a
minimum tax (MT) which was imposed in addition to the taxpayer’s
regular tax. The Code has included MT provisions for both
corporate and individual taxpayers ever since. The current
minimum tax; i.e., the AMT, has generally evolved into its
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