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was $128,054, with RIT liability of $34,492 and AMT liability of
$2,884. Respondent also determined petitioners' liability for
self-employment tax to be $6,250 for the taxable year 1989.
Petitioners' 1990 taxable income as determined by respondent was
$101,547, and their RIT as so determined was $25,372.
Petitioners' liability for the AMT was $3,465. Respondent also
determined petitioners' self-employment tax to be $7,849 for the
taxable year 1990.
For 1988, $6,649 of the qualified section 29 credit of
$12,706 was allowed by respondent. No section 29 credit was
allowed for either 1989 or 1990. An unused section 29 credit of
$6,057 from 1988 was carried over to 1989 pursuant to the section
53 minimum tax credit. See sec. 53(d)(1)(B)(iii). The 1988
credit, along with an unused section 29 credit of $14,210 and AMT
of $2,884 from 1989, was subsequently carried forward to 1990 to
produce a minimum tax credit of $23,151. In 1990, none of
petitioners' $14,729 section 29 credit was allowed, resulting in
a minimum tax credit carryover of $37,880.
In their petition, the Days do not dispute any of the
adjustments to taxable income set forth in the statutory notice
of deficiency. The adjustments to income to which the
petitioners have not assigned error or otherwise placed at issue
in the petition total $7,520 for 1988; $12,200 for 1989; and
$70,456 for 1990. Petitioners instead seek tax relief under
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