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55(b)(1)(A). The amount of the corrected regular tax being
$5,779, respondent determined, pursuant to section 55(a), that
petitioners are liable for AMT of $3,122.
Petitioners argue that the AMT is unfair because it subjects
them to double taxation. The Court would observe that
application of the AMT to petitioners’ 1998 income does not
subject them to double taxation; what the AMT does is defeat
petitioners’ reasonable expectations by depriving them of most of
the tax reduction their allowable personal exemptions,
miscellaneous itemized deductions, and State and local taxes
would otherwise entitle them to. Although the AMT was originally
enacted by Congress “to remedy taxpayer distrust of the system
growing from large numbers of taxpayers with large incomes who
were paying no taxes”, Okin v. Commissioner, 808 F.2d 1338, 1342
(9th Cir. 1987), affg. T.C. Memo. 1985-199, petitioners are part
of the growing number of middle-income people already paying
income tax whose liability therefor is being increased by the
AMT. See, e.g., Editorial, “Fix a Real Tax Problem”, Wash. Post,
May 28, 2003, at A18; Herman, Tax Report, “An Ignored Time Bomb:
Alternative Minimum Tax”, Wall St. J., May 15, 2003, at D2.
However, it remains well established that the AMT’s dilution of
otherwise available tax benefits does not invalidate the AMT.1
1Cf. Job 1:21 (King James) (“the Lord gave, and the Lord
hath taken away; blessed be the name of the Lord”).
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