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In computing alternative minimum taxable income (AMTI), no
deduction is allowed to an individual for, inter alia,
miscellaneous itemized deductions (as defined in section 67(b))
or “for any taxes described in paragraph (1), (2), or (3) of
section 164(a)” unless such taxes are deductible in computing
adjusted gross income; i.e., because incurred in a trade or
business. Sec. 56(b)(1)(A)(i) and (ii).4 Deductions under
sections 163, 164, and 216 are not miscellaneous itemized
deductions, sec. 67(b)(1), (2), (12), and are therefore
deductible in computing AMTI, sec. 56(b)(1)(A)(i).
4 Sec. 56(b)(1)(A) provides:
SEC. 56. ADJUSTMENTS IN COMPUTING ALTERNATIVE MINIMUM
TAXABLE INCOME.
(b) Adjustments Applicable to Individuals.--In
determining the amount of the alternative minimum
taxable income of any taxpayer (other than a
corporation), the following treatment shall apply (in
lieu of the treatment applicable for purposes of
computing the regular tax):
(1) Limitation on deductions.--
(A) In general.--No deduction shall be
allowed--
(i) for any miscellaneous
itemized deduction (as defined in
section 67(b)), or
(ii) for any taxes described
in paragraph (1), (2), or (3) of
section 164(a).
Clause (ii) shall not apply to any amount
allowable in computing adjusted gross income.
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Last modified: May 25, 2011