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from petitioner's brief, the only amount that he ever claimed and
put in issue is the $24,801 disallowed by the Commissioner in the
deficiency notice. The deduction that we approve is accordingly
limited to that $24,801, and to this extent we rule against the
Government.
3. Alternative Minimum Tax
Section 55 imposes "a tax equal to the excess (if any) of
* * * the tentative minimum tax for the taxable year, over * * *
the regular tax for the taxable year." The Commissioner
determined that petitioner's tentative minimum tax exceeded his
regular tax. Petitioner did not specifically challenge the
applicability of the alternative minimum tax in his petition, nor
did he raise the issue or deal with it on brief. He must
therefore, be treated as having abandoned or conceded the issue.
Decision will be
entered under Rule 155.
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Last modified: May 25, 2011