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Revenue Code until the add-on minimum tax was finally repealed by
the Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA),
Pub. L. 97-248, sec. 201(a), 96 Stat. 411, and supplanted by an
amended alternative minimum tax. E.I. du Pont de Nemours & Co.
v. Commissioner, 102 T.C. 1, 18 n.10, affd. 41 F.3d 130 (3d Cir.
1994), and affd. sub nom. Conoco, Inc. v. Commissioner, 42 F.3d
972 (5th Cir. 1995); United States v. Deckelbaum, 784 F. Supp.
1206, 1208 (D. Md. 1992). This TEFRA AMT provision remained in
effect from 1982 until its amendment by the Tax Reform Act of
1986, Pub. L. 99-514, sec. 701, 100 Stat. 2320, which expanded
the AMT for individuals. See S. Rept. 99-313 (1986), 1986-3 C.B.
(Vol. 3) 515, 521.
The post-1986 AMT rules, sections 55-59, were enacted to
establish a floor for tax liability, so that a taxpayer will pay
some tax regardless of the tax breaks otherwise available to him
under the regular income tax rules. See S. Rept. 99-313, supra,
1986-3 C.B. (Vol. 3) at 518. The AMT rules accomplish this goal
by eliminating favorable treatment given to certain items for
purposes of the regular income tax. Secs. 55(b)(2), 56, 57, 58.
The AMT is paid only if, and to the extent that, it exceeds
the taxpayer's regular income tax. Sec. 55(a). The starting
point in computing AMT liability is determining the "alternative
minimum taxable income" (AMTI). AMTI is computed in the same
manner as regular taxable income except that the adjustments
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