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adjustment to AMTI for the $578.08 of tax-exempt interest from
private utility bonds that petitioner reported on his Form 6251.
The record is devoid of an explanation why the tax-exempt
interest was not included in respondent’s computation. On the
basis of the above adjustments, respondent determined in the
notice of deficiency that petitioner was subject to $439.45 of
AMT for 1999.
The AMT provisions of the Internal Revenue Code (Code),
sections 55-59, were enacted to establish a floor for tax
liability, so that a taxpayer will pay some tax regardless of the
exclusions, deductions, and credits otherwise available to him
under the regular income tax statutes. See S. Rept. 99-313, at
518 (1986), 1986-3 C.B. (Vol. 3) 1, 518. The AMT provisions
accomplish this goal by eliminating favorable treatment given to
certain items for purposes of the regular income tax. See secs.
55(b)(2), 56, 57, and 58.
Pursuant to section 55(a), the AMT is applicable only if,
and to the extent that, the “tentative minimum tax” exceeds the
taxpayer’s “regular tax”.1 The starting point in computing the
AMT liability is determining the AMTI, which equals the
taxpayer’s taxable income for the year with the adjustments
provided in sections 56 and 58 and increased by the amount of tax
1 For petitioner, “the term ‘regular tax’ means the regular
tax liability for the taxable year (as defined in sec. 26(b)).”
Sec. 55(c)(1).
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