George and Joan Prosman - Page 3




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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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