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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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Last modified: May 25, 2011