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Congress never intended the tax to apply to taxpayers “in [their]
situation.”
Petitioners could not point out, with specificity, any other
discrepancies in figures between themselves and respondent other
than their repeated references to the aforementioned telephone
conversation that they had with respondent’s agent. Moreover,
petitioners admitted under cross-examination that they did, in
fact, agree to the alternative minimum tax reported on the
computation that respondent’s Appeals Office calculated for them,
and that was stipulated and received into evidence in this case
as Exhibit 3-R.
Finally, petitioner husband concluded his testimony at trial
with the following: “I was willing, after seeing their
computations, I was willing to admit that I probably did owe
alternative minimum tax even though the IRS didn’t do a good job
in proving that to me. I proved it to myself essentially.”
Based on petitioners’ admission, and our review of
respondent’s computation, we hold that petitioners are subject to
the alternative minimum tax provided under section 55.
As to petitioners’ argument that this Court should relieve
them of their tax obligations because “it would be unfair to
apply the alternative minimum tax to people like [them],” we
begin by addressing the event which triggered application of the
alternative minimum tax; in this case, the sale of petitioners’
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Last modified: November 10, 2007