Lauren Ostrow and Joseph Teiger - Page 5

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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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