Noman Earl Holly - Page 2

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          petitioner's 1994 Federal income tax in the amount of $1,675 and            
          an accuracy-related penalty under section 6662(a) in the amount             
          of $335.                                                                    
               After concessions by respondent,2 the only issue for                   
          decision is whether petitioner is subject to the alternative                
          minimum tax (AMT) for the taxable year 1994.3                               
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts and the attached exhibits are                      
          incorporated herein by this reference.  At the time of filing the           
          petition, petitioner resided at Silver Spring, Maryland.                    
               Petitioner timely filed his Federal income tax return for              
          the taxable year 1994.  On his return, petitioner reported                  
          adjusted gross income in the amount of $49,379 and claimed                  
          itemized deductions on Schedule A as follows:                               
          Expense                              Amount                                 
               Real estate taxes                              $725                    

          Rule references are to the tax Court Rules of Practice and                  
               2  Respondent concedes that (1) petitioner is entitled to a            
          foreign tax credit in the amount of $239, and (2) petitioner is             
          not liable for the accuracy-related penalty under sec. 6662(a).             
               3  To the extent that petitioner seeks an abatement of                 
          interest (or a review thereof), he must make such a request to              
          the Commissioner and await a final determination not to abate               
          interest.  Sec. 6404(g); see also Bourekis v. Commissioner, 110             
          T.C. __, __ (1998) (slip op. at 9).                                         

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