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The Senate Finance Committee repeated these statements almost
verbatim in its report.14 S. Rept. 99-313, supra at 521, 1986-3
C.B. (Vol. 3) 521. Although these reports do not explicitly
provide that the computation of an individual’s AMTI also begins
with taxable income, we decline to conclude that the calculation
of AMTI is different for an individual given no clear provision
to that effect in either the statute or the legislative history.
Whereas the House and Senate committee reports both state that
the two regimes are considered “separate” systems, this simply
means, as respondent acknowledges, that two taxes are involved.
The mere fact that the two systems may also be “independent” does
not necessarily mean that they are unrelated in all regards, or,
in other words, parallel.
Petitioners also rely on the fact that section 1.55-1(b),
Income Tax Regs., does not prohibit them from deducting all of
the wages for AMT purposes. Petitioners recognize in this regard
that Congress authorized the Treasury Department to issue
regulations on the AMT regime, that the Commissioner issued two
14 The General Explanation of the 1986 Act also includes
these statements and clarifies that the word “generally” as used
in the discussion on corporations means that regular taxable
income is not used only where the taxpayer’s tax base is other
than taxable income; e.g., unrelated business taxable income,
real estate investment trust taxable income, or life insurance
company taxable income. General Explanation of the 1986 Act,
supra at 436-437. The General Explanation of the 1986 Act states
that a technical correction may be necessary to effectuate the
exception to the general rule. Id. at 436 n.5.
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