- 3 - On their Federal income tax return for 1995, petitioners reported adjusted gross income (AGI) in the amount of $83,143.1 On Schedule A of their 1995 return, petitioners claimed, among other deductions, the following itemized deductions: Expense Amount Taxes paid $8,824.82 Job expenses and other miscellaneous deductions, above the 2-percent floor 28,589.632 Total 37,414.45 For 1995, petitioners reported income prior to the deduction for exemptions of $37,843, taxable income of $32,843, and total tax of $4,924. There is no dispute that petitioners incurred expenses as claimed on their 1995 return. In the notice of deficiency, respondent determined that petitioners were subject to the AMT for the tax year in issue. Respondent computed an AMT in the amount of $7,612 for petitioners' 1995 tax year, and determined a deficiency in petitioners' tax in the amount of $2,688. OPINION Petitioners contend that respondent's application of section 55 is inequitable. 1 This amount includes $982 in "Taxable refunds, credits, or offsets of state and local income taxes". 2 This amount consists of unreimbursed employee business expenses incurred by petitioner while working for Command Systems.Page: Previous 1 2 3 4 5 Next
Last modified: May 25, 2011