Thomas N. Rawlins - Page 3

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               Alternative minimum taxable income:                                    
                    Taxable income (before                                            
                    deductions for exemptions)              $30,498                   
                    Adjustments:                                                      
                    Misc. itemized deductions     12,315                              
                    Taxes                          1,861                              
                    Total adjustments                        14,176                   
                                                            44,674                    
                    Exemption amount                         20,000                   
                    Tentative minimum taxable income        24,674                    
                                                             x 24%                    
                    Tentative minimum tax                   5,922                     
                    Regular tax                               4,274                   
                    AMT                                     $1,648                    
          Petitioner does not challenge respondent's calculation of the               
          tax.  He argues, rather, that the AMT imposed by section 55(a)              
          unconstitutionally distinguishes between the expenses of self-              
          employed individuals and employees in violation of the Due                  
          Process Clause of the Fifth Amendment.                                      
               Generally, under the AMT scheme an individual's tax                    
          liability is equal to 24 percent of the so-called "tentative                
          minimum taxable income", which is the excess of the "alternative            
          minimum taxable income" (AMTI) over the exemption amount provided           
          by section 55(d)(1).  Sec. 55(b)(1).  AMTI is determined,                   
          generally, through adjustments to the taxpayer's taxable income             
          pursuant to sections 56, 57, and 58.  Sec. 55(b)(2).  In                    
          determining the AMTI of individuals, no deduction is allowed for            
          miscellaneous itemized deductions.  Sec. 56(b)(1)(A)(i).  The               
          trade or business expenses of a self-employed taxpayer, however,            
          are deductible "above the line" in arriving at adjusted gross               
          income under section 62(a)(1); generally these deductions are not           





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