- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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