- 7 - applicable exemption amount of $45,000 by $23,832.44. See sec. 55(d)(1)(A)(i). Petitioners' "tentative minimum tax" is therefore 26 percent of that excess, or $6,196.43. See sec. 55(b)(1)(A)(i)(I). Because petitioners' tentative minimum tax exceeds petitioners' regular tax of $5,111, petitioners are liable for the alternative minimum tax in the amount of such excess; i.e., $6,196.43 less $5,111, or $1,085.43. Petitioners do not challenge the mechanics of the foregoing computation. Rather, petitioners contend that they are not liable for the alternative minimum tax for two independent reasons. First, petitioners contend that the elimination of personal exemptions under the alternative minimum tax adversely affects large families and results in an application of the alternative minimum tax that is contrary to congressional intent. In this regard, petitioners argue that legislative history demonstrates that the alternative minimum tax was intended to limit items of tax preference, not personal exemptions. Second, petitioners argue that the alternative minimum tax violates various constitutional rights, particularly the right to religious freedom. A. Congressional Intent We begin with petitioners' contention that they are not liable for the alternative minimum tax because such tax was not intended to apply to them. In this regard, petitioners emphasize that they did not have a single item of tax preference, and theyPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011