Lawrence Moore - Page 3

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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.                                                 
               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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