Edward A. Birts - Page 4




                                        - 3 -                                         
               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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