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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.
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Last modified: May 25, 2011