Mark Spitz - Page 18

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          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 the Court finds no              
          language supporting an inference of such intent.  See id.                   
          Therefore, this Court will not further consider petitioner’s                
          arguments based upon his interpretation of congressional intent.            
               Petitioner also advances several “policy and legal                     
          considerations”.  Essentially, petitioner is arguing, under                 
          principles of equity, he should be allowed to fully deduct his              
          AMT capital losses against AMT ordinary income and carry back               
          excess AMT capital losses to reduce his AMTI in the years at                
          issue.  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.                          
               This Court has previously stated:                                      
                    The unfortunate consequences of the AMT in                        
               various circumstances have been litigated since                        
               shortly after the adoption of the AMT.  In many                        
               different contexts, literal application of the AMT                     
               has led to a perceived hardship, but challenges                        
               based on equity have been uniformly rejected.                          
               * * *                                                                  
                    * * * “it is not a feasible judicial                              
               undertaking to achieve global equity in taxation                       





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