¹See JCT Present Law and Background Relating to Marriage Tax Penalty, Education Tax Incentives, the Alternative Minimum Tax, and Expiring Tax Provisions (JCX-39-99, 6/22/99); see also Kern, "The AMT Trap," 188 J. of Accountancy 87 (October 1999).

²See Notice 2000-26, IRB 2000-17, 954.