context: The courts have recognized the importance of a preference reduction in section 58(h).
citation_a.signal: see
citation_a.identifier: 842 F.2d 181, 181
citation_a.parenthetical: "Standing alone -- that is, without section 58(h) -- section 56(a) would impose minimum tax on tax-preference items even though the items never conferred a tax benefit on the taxpayer."
citation_a.sentence: See id. at 669 (section 58(h) “reflected a congressional concern to avoid imposition of the minimum tax on preferences in situations where the preferences did not produce tax benefits”), aff'd. 842 F.2d at 181 (“Standing alone — that is, without section 58(h) — section 56(a) would impose minimum tax on tax-preference items even though the items never conferred a tax benefit on the taxpayer.”); Occidental Petroleum Corp. v. Commissioner, 82 T.C. at 824 (“Plainly, in enacting section 58(h), Congress was concerned about not imposing the minimum tax on tax preferences where such tax preferences did not result in a tax benefit.”); see also Occidental Petroleum Corp. v. United States, 231 Ct. Cl. 334, 685 F.2d 1346 (1982) (taxpayer liable for minimum tax for years in which nonbeneficial preferences arose, which preceded enactment of section 58(h)).
citation_b.signal: see also
citation_b.parenthetical: taxpayer liable for minimum tax for years in which nonbeneficial preferences arose, which preceded enactment of section 58(h
citation_b.sentence: See id. at 669 (section 58(h) “reflected a congressional concern to avoid imposition of the minimum tax on preferences in situations where the preferences did not produce tax benefits”), aff'd. 842 F.2d at 181 (“Standing alone — that is, without section 58(h) — section 56(a) would impose minimum tax on tax-preference items even though the items never conferred a tax benefit on the taxpayer.”); Occidental Petroleum Corp. v. Commissioner, 82 T.C. at 824 (“Plainly, in enacting section 58(h), Congress was concerned about not imposing the minimum tax on tax preferences where such tax preferences did not result in a tax benefit.”); see also Occidental Petroleum Corp. v. United States, 231 Ct. Cl. 334, 685 F.2d 1346 (1982) (taxpayer liable for minimum tax for years in which nonbeneficial preferences arose, which preceded enactment of section 58(h)).