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Schedule A medical deduction 4,767.13
Less: AMT deductible amount -2,690.72
Adjustment 2,076.41
OPINION
Our analysis necessarily begins with section 55, the section
of the Internal Revenue Code that imposes the alternative minimum
tax. Initially, we note that the alternative minimum tax is
imposed in addition to the regular tax and that the "regular tax"
is, as relevant herein, the income tax computed on taxable income
by reference to the pertinent tax table. See sec. 55(a), (c)(1).
In petitioners' case, the "regular tax" is $5,111; i.e., the
amount reported on line 38 of petitioners' Form 1040.
Pursuant to section 55(a), the alternative minimum tax is
the difference between the "tentative minimum tax" and the
"regular tax". As relevant herein, the "tentative minimum tax"
is 26 percent of the excess of a taxpayer's "alternative minimum
taxable income" over an exemption amount of $45,000. See sec.
55(b)(1)(A)(i)(I), (b)(2), (d)(1)(A)(i).
Section 55(b)(2) defines the term "alternative minimum
taxable income". As relevant herein, the term "alternative
minimum taxable income" means the taxpayer's taxable income for
the taxable year determined with the adjustments provided in
section 56 and increased by the amount of items of tax preference
described in section 57. Petitioners had no items of tax
preference in 1994. Accordingly, alternative minimum taxable
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