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is not bound in any given year to allow the same treatment
permitted in a previous year. See Lerch v. Commissioner, 877
F.2d 624, 627 n.6 (7th Cir. 1989); Knights of Columbus Council
No. 3660 v. United States, 783 F.2d 69 (7th Cir. 1986); Corrigan
v. Commissioner, 155 F.2d 164 (6th Cir. 1946). Taxpayers have no
right to continue a prior tax treatment that was wrong either on
the law or under the facts. See Thomas v. Commissioner, 92 T.C.
206, 226-227 (1989). "The mere fact that petitioner may have
obtained a windfall in prior years does not entitle [him] * * *
to like treatment for the taxable year here in issue." Union
Equity Coop. Exch. v. Commissioner, 58 T.C. 397, 408 (1972),
affd. 481 F.2d 812 (10th Cir. 1973); see also Schaeffer v.
Commissioner, T.C. Memo. 1994-227.
Petitioner also claims that the language on his tax forms
did not clearly indicate to him that he should perform the
computation to determine whether he would owe the AMT because the
forms said only that a taxpayer "may" owe tax because of the AMT.
We do not accept petitioner's forced interpretation of "may" as
mitigation to respondent's negligence determination in this
setting.
We find most persuasive the fact that petitioner had been
audited and agreed that he owed the AMT for 1991. That
concession occurred before petitioner's 1995 return filing.
Petitioner also admitted that he had received training on the AMT
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