- 4 -
noncorporate taxpayers, the tentative minimum tax is 26 percent
of the first $175,000 of "taxable excess" (alternative minimum
taxable income (AMTI) less the exemption amount) and 28 percent
of any remaining taxable excess. AMTI is the taxable income of
the taxpayer for the taxable year, determined with the
adjustments provided in sections 56 and 58. Sec. 55(b)(2).
Section 56(b)(1) provides that, for purposes of calculating AMTI,
no deduction is allowed for miscellaneous itemized deductions and
State and local real property taxes paid, unless such taxes are
deductible in determining adjusted gross income. The exemption
amount for an unmarried taxpayer who is not a surviving spouse is
$33,750. Sec. 55(d)(1)(B).
We now turn to the question of whether respondent correctly
determined petitioner's AMT liability. To compute petitioner's
AMT liability, respondent started with the amount of income
reported by petitioner on his return before deducting the
personal exemption ($16,337).4 Respondent then added to this
amount the deductions claimed for: (1) Miscellaneous itemized
deductions ($30,247) and (2) real estate taxes ($725). As a
result, respondent determined petitioner's AMTI to be $47,309.
Since this amount exceeded the exemption amount for unmarried
taxpayers by $13,559, respondent calculated the tentative minimum
4 Because of a mathematical error, the amount which should
have been reflected on petitioner's return and respondent's
computation is $16,377.
Page: Previous 1 2 3 4 5 Next
Last modified: May 25, 2011