Lawrence Moore - Page 4

                                        - 4 -                                         
          Revenue Code until the add-on minimum tax was finally repealed by           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                

Page:  Previous  1  2  3  4  5  6  7  8  Next

Last modified: May 25, 2011