- 3 -
Petitioners 1994 1995
Charles C. Allen III and Barbara N. Allen $21,321 $12,107
Charles C. Allen, Jr. 21,324 12,015
John R. Allen and Estate of Sally F. Allen 21,395 -
John R. and Judith M. Allen - 12,108
John R. Allen, Jr., and Susan S. Allen 21,394 12,107
Warren L. Allen 6,388 1,970
Warren L. Allen, Jr. 36,197 20,582
Amantha S. Allen 36,197 20,582
Following concessions in docket Nos. 1291-00 and 1292-00, we
must decide whether the wage-expense limitation of section
280C(a) enters into the calculation of alternative minimum
taxable income (AMTI). As relevant herein, section 280C(a)
limits a taxpayer’s wage expense to the amount of the expense
that exceeds the amount of a targeted jobs credit (TJC)
determined under section 51(a). We hold that section 280C(a)
enters into the calculation of a taxpayer’s AMTI.
Background
All facts were stipulated and are so found. The stipulated
facts and the exhibits submitted therewith are incorporated
herein by this reference. During the subject years, each
petitioner,3 with the exception of Warren L. Allen and Charles C.
Allen, Jr., filed a joint Federal income tax return with his
wife. Charles C. Allen III was the husband of Barbara N. Allen.
John R. Allen was the husband of Sally F. Allen during 1994, and
3 We hereinafter refer to Charles C. Allen III, Charles C.
Allen, Jr., John R. Allen, John R. Allen, Jr., Warren L. Allen,
and Warren L. Allen, Jr., as the sole petitioners.
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