Allyson Christina Briggs - Page 10

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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:                                             
                    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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