George and Joan Prosman - Page 4




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               Section 55(a) imposes a tax equal to the excess of the                 
          tentative minimum tax over the regular tax.  The tentative                  
          minimum tax for noncorporate taxpayers is equal to 26 percent of            
          the amount (the taxable excess), as does not exceed $175,000, by            
          which the alternative minimum taxable income (AMTI) exceeds the             
          exemption amount, plus 28 percent of such taxable excess as                 
          exceeds $175,000.  See sec. 55(b)(1)(A).  The exemption amount              
          for married couples filing a joint return is $45,000.  See sec.             
          55(d).                                                                      
               AMTI equals the taxpayer's taxable income for the year with            
          the adjustments provided in sections 56 and 58 and increased by             
          the amount of tax preference items described in section 57.  See            
          sec. 55(b)(2).  In calculating AMTI, no deduction is allowed for            
          miscellaneous itemized deductions and State and local taxes paid,           
          unless such amounts are deductible in determining AGI.  See sec.            
          56(b)(1).  Also, no deduction for personal exemptions under                 
          section 151 is allowed.  See sec. 56(b)(1)(E).                              
               In computing petitioners' AMTI for the year in issue,                  
          respondent disallowed petitioners' deductions for taxes paid and            
          for job expenses and other miscellaneous itemized deductions.  We           
          have reviewed respondent's computations of the AMT and find that            
          they comport with the provisions of sections 55 and 56.                     
               Petitioners, however, contend that the AMT was intended to             
          apply to high income earners rather than to lower income                    
          taxpayers, such as themselves.  Petitioners contend that if                 




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