Roy E. and Linda Day - Page 4

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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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