To Praise the AMT Or to Bury It (Alternative Minimum Tax‪)‬

I. INTRODUCTION The alternative minimum tax (AMT) has recently become a cause celebre because many more taxpayers are now subject to it than originally envisioned at the time of its enactment in 1969 (and, indeed, than after any of its several modifications over the years). (1) As such, it has been discussed and criticized in the press and by tax professionals and academics, most recently in Tax Notes by four former Internal Revenue Service (Service) commissioners who advocated scrapping it entirely. (2) The American Bar Association expressed similar views in early 2004 when it recommended that "Congress reduce the federal tax burdens and compliance costs attributable to the Alternative Minimum Tax on individuals by repealing the individual AMT." (3) The AMT was also the subject of a Revenue and Tax Policy Brief by the Congressional Budget Office in April 2004. (4) The criticism has questioned the wisdom of the inadvertent expansion of the AMT in coverage, that is, the number of taxpayers who will be subject to it. (5) This expansion of the AMT's coverage has largely resulted from the reduction in rates of the regular tax without a concomitant reduction in rates of the AMT. (6) The focus of the recent discussion of the AMT, however, has been on a glass half empty instead of on a glass half full.