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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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