Edward A. Birts - Page 7




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          described in section 57.  Petitioner had no items of tax                    
          preference in 1997.  Accordingly, alternative minimum taxable               
          income means petitioner’s taxable income determined with the                
          adjustments provided in section 56.                                         
               Petitioner’s taxable income for 1997 was $4,147, the amount            
          reported on line 38 of Form 1040.                                           
               As relevant herein, the adjustments provided in section                
          56(b) are twofold.  First, section 56(b)(1)(A)(i) states that no            
          deduction shall be allowed for any miscellaneous itemized                   
          deduction as defined in section 67(b), such as unreimbursed                 
          employee expenses, in computing alternative minimum taxable                 
          income.  Second, section 56(b)(1)(E) states that no personal                
          exemptions shall be allowed in computing alternative minimum                
          taxable income.                                                             
               The effect of section 56(b)(1)(A)(i) and (b)(1)(E) is to               
          increase petitioner’s taxable income by: (1) $26,903, the amount            
          claimed on petitioner’s Schedule A for miscellaneous itemized               
          deductions (i.e., unreimbursed employee expenses); and (2)                  
          $5,300, the amount claimed on petitioner’s Form 1040 for personal           
          exemptions.                                                                 
               After taking into account the foregoing two adjustments,               
          petitioner’s alternative minimum taxable income for 1997 equals             
          $36,350.  Alternative minimum taxable income exceeds the                    
          applicable exemption amount of $22,500 by $13,850.  See sec.                






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