- 18 - 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 taxationPage: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
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