- 3 -
Charitable contributions 885
Unreimbursed job-related
legal expenses 30,247
Moving expenses 1,145
Total 33,002
The taxable income reflected on line 37 of petitioner's return is
$13,927, and the total tax reflected on line 53 of the return,
after being reduced by a foreign tax credit, is $1,850. During
the taxable year 1994, petitioner was a retired Government
employee. On his return for the taxable year 1994, petitioner
indicated "Self-employed consultant" as his occupation.
Respondent does not dispute the correctness of any item of
income, deduction, or credit reflected on petitioner's return for
the taxable year 1994. Respondent, however, argues that
petitioner is subject to the AMT, and, accordingly, has
determined a deficiency in the amount of $1,675. Petitioner
argues that the AMT was created to apply only to higher income
taxpayers, and, accordingly, the AMT is not applicable in this
instance because he was not a high income taxpayer during the
taxable year in issue.
OPINION
Section 55(a) imposes an AMT on taxpayers to the extent that
their "tentative minimum tax", as calculated pursuant to section
55(b), exceeds the "regular tax", defined in section 55(c)(1) as
the regular tax liability for the taxable year reduced by the
foreign tax credit. Section 55(b)(1)(A) provides that for
Page: Previous 1 2 3 4 5 Next
Last modified: May 25, 2011