Thomas N. Rawlins - Page 2

               Respondent determined a deficiency in petitioner's 1992                
          Federal income tax in the amount of $1,648.  Petitioner resided             
          in Wheelersburg, Ohio, at the time the petition was filed.                  
               The issue is whether petitioner is subject to the                      
          alternative minimum tax (AMT) imposed by section 55.                        
               Petitioner is an electrician and a union member.  Although             
          his job assignments are generally for relatively short periods of           
          time, he works as a common law employee for each of his                     
          employers.  Petitioner filed a 1992 Federal income tax return as            
          a married taxpayer filing separately reflecting the following               
          information:                                                                
               Adjusted gross income                        $48,271                   
               Schedule A--Itemized deductions                                        
               Taxes                              $1,861                              
               Home mortgage interest             1,647                               
               Contributions                      1,950                               
               Misc. itemized deductions:                                             
               Unreimbursed employee                                                  
               expenses                 $13,230                                       
               Tax preparation               50                                       
               Sec. 67 limit                (965)                                     
                                        12,315                                        
               Total itemized deductions                    17,773                    
               Personal exemptions                           6,900                    
               Taxable income                               23,598                    
               Income tax liability                         $4,274                    
               Respondent does not challenge any item of income or the                
          deductions.  Rather, respondent determined that petitioner had an           
          additional AMT liability in the amount of $1,648, calculated as             
          follows:                                                                    









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