Philip and Margery Skalka - Page 17

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          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”.5  The starting point in computing the             
          AMT liability is determining the alternative minimum taxable                
          income (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 preference items set forth in                
          section 57.  To determine the taxable amount of AMTI, the AMTI is           
          reduced by an exemption amount, which for taxpayers filing a                
          joint return is $45,000, subject to a gradual phaseout of the               
          exemption amount as AMTI exceeds $150,000.  See sec. 55(d)(1),              
          (3).  The applicable AMT rates are then applied to the AMTI, as             
          reduced by the exemption amount, to determine the tentative                 
          minimum tax (TMT).  See sec. 55(b).  For taxpayers reporting                
          capital gains on Form 1040, the TMT is the lesser of (1) the                
          amount of AMT determined without regard for section 55(b)(3), or            


               5  For petitioners, “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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