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In its efforts to guide money to the states, our federal government annually passes up more than $75 billion in potential revenue under a single provision of the Tax Code. That provision, section 164 of the Code, allows itemizing taxpayers to deduct the cost of the state and local income, property, and (to a limited extent) sales taxes they paid during the tax year. The eye-popping size of that number makes section 164 a perennial issue in tax policy circles, and as one of the deductions omitted from the Alternative Minimum Tax's (AMT) parallel tax universe, the section is also a key component of debates about the AMT. Indeed, the President's Advisory Panel on Tax Reform recommends eliminating the deduction to pay for its proposed AMT reform.

Publication Citation

82 Ind. L.J. 673-710 (2007)