Edward A. Birts - Page 3




                                        - 2 -                                         
               Respondent determined a deficiency in petitioner’s Federal             
          income tax for the taxable year 1997 in the amount of $2,982.               
          The deficiency is attributable solely to the alternative minimum            
          tax prescribed by section 55.                                               
               The issue for decision is whether petitioner is liable for             
          alternative minimum tax.  We hold that he is.                               
          Background                                                                  
               Some of the facts have been stipulated, and they are so                
          found.  Petitioner resided in Houston, Texas, at the time that              
          his petition was filed with the Court.                                      
               Petitioner filed a Federal income tax return, Form 1040, for           
          1997.  On his return, petitioner listed his filing status as                
          married filing separately, and he claimed deductions for two                
          personal exemptions.  Petitioner reported adjusted gross income             
          (AGI) in the amount of $37,850, consisting solely of wages from             
          employment.                                                                 
               In addition, petitioner itemized deductions on Schedule A.             
          In this regard, petitioner claimed total deductions in the amount           
          of $28,403, consisting of charitable contributions in the amount            
          of $1,500 and miscellaneous itemized deductions (in the form of             
          unreimbursed employee expenses) in the net amount of $26,903,               
          calculated as follows:                                                      
               Miscellaneous itemized deductions                                      
               (Unreimbursed employee expenses)   $27,660                             
               Less: 2% AGI                            -757                           
               Net amount                            26,903                           





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