Sandra R. Murray and Khaled M. Abouelnoor - Page 8

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          6251.  Use of this worksheet demonstrates that petitioners should           
          have completed Form 6251.                                                   
               Second, we observe that the AMT is imposed in addition to              
          the “regular tax”, which is, in general, the income tax computed            
          on taxable income by reference to the tax table or rate schedule.           
          Secs. 26(b), 55(a), (c)(1); see secs. 1(a)(1), 3(a).  Petitioners           
          reported zero regular tax for 2002 on line 55 of their return.              
               Therefore, we now turn to section 55 that imposes the AMT.             
          The AMT is the difference between the “tentative minimum tax” and           
          the regular tax.  Sec. 55(a).  As relevant herein, the tentative            
          minimum tax is 26 percent of the excess of a taxpayer’s                     
          “alternative minimum taxable income” over an exemption amount of            
          $49,000.  Sec. 55(b)(1)(A)(i)(I), (b)(2), (d)(1)(A)(i).                     
               As relevant herein, section 55(b)(2) defines alternative               
          minimum taxable income as the taxpayer’s taxable income for the             
          taxable year determined with the adjustments provided in section            
          56 and increased by the amount of items of tax preference                   
          described in section 57.4  As previously stated, petitioners had            
          no items of tax preference in 2002.  Therefore, the alternative             
          minimum taxable income is petitioners’ taxable income determined            
          with the adjustments provided in section 56.                                



               4  As relevant herein, sec. 63 defines taxable income as               
          adjusted gross income less (1) Schedule A itemized deductions and           
          (2) personal exemptions.                                                    





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