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increase the sec. 29, I.R.C., credits available under
the sec. 29(b)(5), I.R.C., limitation. First Chicago
Corp. v. Commissioner, 88 T.C. 663 (1987), affd. 842
F.2d 180, 181 (7th Cir. 1988), distinguished.
Marcia Allen Broughton, for petitioners.
Michael A. Yost, Jr., for respondent.
OPINION
NIMS, Judge:* Respondent determined deficiencies in Roy E.
and Linda Day's (petitioners or the Days) Federal income tax for
the taxable years 1988, 1989, and 1990 in the amounts of $6,791,
$14,825, and $10,127, respectively. The only issue for decision
is whether petitioners can utilize section 59(g) to compute their
tentative minimum taxable income, thereby increasing the extent
to which they can apply qualified section 29 credits against
their regular income tax for the taxable years 1988 through 1990.
For the reasons that follow, we hold that they cannot.
For ready reference, the following acronyms are used
throughout this Opinion:
TMT- tentative minimum tax
TMTI- tentative minimum taxable income
RIT- regular income tax
AMT- alternative minimum tax
AMTI- alternative minimum taxable income
*This case was reassigned to Judge Arthur L. Nims, III, by
Order of the Chief Judge.
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