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$126,600, he calculated the section 68 limitation on his
otherwise allowable itemized deductions and determined he was
required to reduce his total itemized deductions by $7,400.08.
Thus, petitioner’s total itemized deductions were limited to
$1,850.02. Accordingly, petitioner decided to deduct the section
63(c) standard deduction for a single individual in the amount of
$4,300 in lieu of electing to deduct the lesser limited itemized
deduction amount of $1,850.02. Petitioner then computed his 1999
taxable income and income tax liability using the maximum capital
gains rate method as follows:
Adjusted gross income $1,015,759.94
Less: Standard deduction 4,300.00
Taxable income $1,011,459.94
Total tax (sec. 1(c), (h)) $210,049.99
Because petitioner claimed the standard deduction, he was
not required to file Schedule A, Itemized Deductions. However,
petitioner filed a blank Schedule A with his income tax return,
reporting absolutely no information or deductions on the form.
Further, petitioner did not report any AMT on his 1999 Form 1040,
nor did he include Form 6251, Alternative Minimum Tax--
Individuals, with his return.
After receiving petitioner’s income tax return, respondent
sent petitioner correspondence informing petitioner that Form
6251 was required to process the return accurately. Respondent
requested that petitioner file a Form 6251 timely. Thereafter,
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