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taxpayers.13 In contrast to the MT, the AMT was imposed on a tax
base similar to taxable income. The most notable differences
between the bases were that, in computing AMTI, a long-term
capital gain deduction was not allowed and itemized deductions
could be effectively disallowed. As to both taxable bases, the
NOL deduction and the basis of property were the same.
Through TEFRA, Congress repealed the MT for noncorporate
taxpayers and replaced it with a revised form of AMT. For the
computation of AMTI, Congress generally: (1) Incorporated the
old MT preferences by causing those amounts to increase AMTI
relative to taxable income and (2) created new preferences which
were either not deductible or not excludable from gross income.
Congress also disallowed certain itemized deductions allowable in
computing taxable income and provided for a separate alternative
tax NOL deduction.
The TEFRA AMT provision remained in effect from 1982 until
its amendment by the 1986 Act, which expanded the AMT for
individuals. S. Rept. 99-313, at 515, 521 (1986), 1986-3 C.B.
(Vol. 3) 515, 521. Through that act, Congress repealed the MT
13 Although the Revenue Act of 1978, Pub. L. 95-600,
92 Stat. 2763, purported to repeal the add-on minimum tax for
individuals and replace it with a new AMT formulation beginning
in 1979, other sources indicate that the two provisions
co-existed in the Code until the add-on minimum tax was finally
repealed by the Tax Equity and Fiscal Responsibility Act of 1982,
Pub. L. 97-248, sec. 201(a), 96 Stat. 411, and supplanted by an
amended alternative minimum tax. See, e.g., Day v. Commissioner,
108 T.C. 11, 14 (1997), and the cases cited therein.
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