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from the high tax bracket of a donor with substantial
income to a minor with little or no other income.
S. Rept. 92-437 at 62 (1971), 1972-1 C.B. 559, 593. To the same
effect, see Staff of the Joint Committee on Internal Revenue
Taxation, General Explanation of the Revenue Act of 1971 at 60
(J. Comm. Print 1971). Thereupon, the Congress enacted the
predecessor of the provision we deal with, in section 301(a) of
the Revenue Act of 1971 (RA 1971), Pub. L. 92-178, 85 Stat. 497,
520, which provided as follows:
SEC. 301. UNEARNED INCOME OF TAXPAYERS WHO ARE DEPENDENTS
OF OTHER TAXPAYERS.
(a) Limitation of Standard Deduction.--Section 141
(relating to the standard deduction) is amended by adding at
the end thereof the following new subsection:
“(e) Limitations in Case of Certain Dependent
Taxpayers.--In the case of a taxpayer with respect to whom a
deduction under section 151(e) is allowable to another
taxpayer for the taxable year--
“(1) the percentage standard deduction shall be
computed only with reference to so much of his adjusted
gross income as is attributable to his earned income
(as defined in section 911(b)), and
“(2) the low income allowance shall not exceed his
earned income for the taxable year.”
The Tax Reduction and Simplification Act of 1977
Section 102(a) of the Tax Reduction and Simplification Act
of 1977, Pub. L. 95-30, 91 Stat. 126, 135, revised the definition
of taxable income by introducing the concept of a zero bracket
amount, hereinafter sometimes referred to as ZBA. The standard
deduction limitation as to dependent taxpayers was moved from
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