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additional tax liability.” Petitioner argues that the only way
to comply with congressional intent is to allow him to carry back
his AMT capital loss. Throughout his opening brief and reply
brief, petitioner focuses heavily on his interpretation of
congressional intent to support various arguments.
Petitioner relies on the Senate report to the Tax Reform Act
of 1986, Pub. L. 99-514, 100 Stat. 2085, as authority for the
asserted congressional intent. See S. Rept. 99-313 (1986), 1986-
3 C.B. (Vol. 3) 1. Petitioner does not offer a specific citation
but instead cites the Senate report generally. The Senate report
addresses the AMT provisions on pages 515-540. Id. at 515-540,
1986-3 C.B. (Vol. 3) at 515-540. The Senate report does not
directly support petitioner’s interpretation of congressional
intent, and we find no language supporting an inference of such
intent. See id. Therefore, we do not further consider
petitioner’s arguments based on his interpretation of
congressional intent.
Petitioner also advances several “policy and legal
considerations”. Essentially, petitioner is arguing that, under
principles of equity, he should be allowed to carry back his AMT
capital loss to reduce his AMTI. Petitioner feels that applying
the capital loss limitations of sections 1211 and 1212 to the
calculation of his AMTI results in harsh and unfair tax
consequences.
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