Roy E. and Linda Day - Page 2

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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.                                                  

                  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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