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The Commissioner sent petitioner a notice of deficiency
dated March 30, 2001, stating his determination that petitioner
is liable for the alternative minimum tax prescribed by section
55 in the amount of $4,233.
OPINION
Since 1969, the Internal Revenue Code has included minimum
tax provisions for both corporate and individual taxpayers. Tax
Reform Act of 1969 (TRA 1969), Pub. L. 91-172, 83 Stat. 487.
Congress enacted the minimum tax to prevent corporate and
individual taxpayers from aggregating deductions to the point
where they pay either no tax or a "shockingly low" tax. First
Chicago Corp. v. Commissioner, 842 F.2d 180, 181 (7th Cir. 1988),
affg. 88 T.C. 663 (1987). Section 301 of the TRA 1969, 83 Stat.
580, imposed a minimum tax on certain tax preference items to be
added on to a taxpayer's other tax liability. The provisions
remained in effect, with only minor changes, as the only minimum
tax formulation in the Internal Revenue Code until 1978. See
Revenue Act of 1978, Pub. L. 95-600, sec. 421(a), 92 Stat. 2871;
First Chicago Corp. v. Commissioner, supra; Day v. Commissioner,
108 T.C. 11 (1997).
The Revenue Act of 1978 was supposed to repeal the add-on
minimum tax for individuals and replace it with a new alternative
minimum tax (AMT) beginning in 1979. Other sources indicate,
however, that the two provisions co-existed in the Internal
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