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After taking into account itemized deductions and personal
exemptions, petitioner reported taxable income in the amount of
$4,147. Using the tax table prescribed by section 3 for
individuals, petitioner reported tax in the amount of $619.
Petitioner did not attach Form 6251, Alternative Minimum
Tax–Individuals, to his 1997 return, nor did petitioner report
any liability for alternative minimum tax on his return.
In October 1999, respondent issued a notice of deficiency to
petitioner for the taxable year 1997. In the notice, respondent
did not disallow any of the itemized deductions or personal
exemptions claimed by petitioner on his return. Rather,
respondent determined that petitioner is liable for alternative
minimum tax, as prescribed by section 55, in the amount of
$2,982.
Petitioner filed a petition contesting respondent’s
deficiency determination. In the petition (as well as at trial),
petitioner contends that he is not the type of person who should
be liable for alternative minimum tax.
Discussion
Deferring for the moment the fundamental issue whether
petitioner is liable for alternative minimum tax, the following
computation shows the proper amount of such tax:
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