Chad W. and Aliza Kold-Warren - Page 6




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          an issue at trial.  In their computation, petitioners point out             
          that alternative minimum tax of $1,553 was reported on their                
          return for 2002, but no alternative minimum tax was determined              
          “per exam”.  In effect, petitioners’ computation suggests that              
          alternative minimum tax is not applicable because none was                  
          computed in the notice of deficiency.                                       
               We disagree.  There is nothing in the record to suggest that           
          respondent conceded the alternative minimum tax in this case, and           
          petitioners have shown no reason why the alternative minimum tax            
          is not applicable.  No alternative minimum tax was determined by            
          respondent in the notice of deficiency because there was no                 
          excess of tentative minimum tax over regular tax, based upon the            
          adjustments determined in the notice of deficiency.  See sec.               
          55(a).  Based upon the adjustments redetermined in these                    
          proceedings, the situation is different.  This is simply a                  
          computational matter.  We agree with respondent that alternative            
          minimum tax is applicable, and we agree with the amount computed            
          in respondent’s revised computation, $1,688.                                
               Item No. 5:  Petitioners claim a child tax credit of $500,             
          the same amount claimed on their return, whereas respondent’s               
          revised computation allows zero.  Respondent disallowed the child           
          tax credit in the notice of deficiency as a result of the                   
          application of the limitation based on petitioners’ adjusted                
          gross income.  See sec. 24(b)(1).  Similarly, based upon the                







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