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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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