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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