Rolly J. and Joann M. Sorrentino - Page 4




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               State and local taxes paid                             $ 6,033         
               Home mortgage interest                                   4,062         
               Charitable contributions                                 4,077         
               Job expenses and other miscellaneous deductions                        
          (in excess of 2% of adjusted gross income)            21,511                
               Total itemized deductions                            $35,683           

          Petitioners' tax, prior to credits, was $4,091.  Respondent made            
          no adjustments to either the income or the itemized deductions on           
          petitioners' return.  Petitioners' return also included a Form              
          6251, Alternative Minimum Tax–-Individuals (the form), which                
          reflected zero alternative minimum tax.  Respondent determined              
          that petitioners were liable for the AMT.                                   
               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            
          so much of the taxable excess as does not exceed $175,000.  See             
          sec. 55(b)(1)(A)(i).  The taxable excess is that amount by which            
          the alternative minimum taxable income (AMTI) exceeds the                   
          exemption amount.  See sec. 55(b)(1)(A)(ii).  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                 
          determined with the adjustments provided in section 56.  See sec.           
          55(b)(2).  In calculating AMTI, no deduction is allowed for                 
          miscellaneous itemized deductions or for State and local taxes              
          paid, unless such amounts are deductible in determining adjusted            






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