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provided in sections 56 and 58 are taken into account for AMTI,
and the tax preference items set forth in section 57 are not
permitted to reduce AMTI. Sec. 55(b)(2). To determine the
taxable amount of AMTI, the AMTI is reduced by an exemption
amount, which in this case is $33,750, subject to a gradual
phase-out of the exemption amount as AMTI exceeds $112,500. Sec.
55(d)(1), (3). The AMT rate is then applied to AMTI, as reduced
by the exemption amount. Sec. 55(b). For the taxable year at
issue in this case, the applicable AMT rate is 26 percent. The
figure resulting from the application of the AMT rate to the AMTI
is the tentative minimum tax (TMT).
Next, the regular income tax is compared to TMT. If TMT is
greater than the regular income tax, the TMT is the final tax
liability for the taxable year. Sec. 55(a).
In petitioner's case,2 the regular income tax is $1,219, the
amount petitioner reported on lines 40 and 49 of his Form 1040.
Pursuant to section 55(a), the AMT is the difference between the
tentative minimum tax and the regular tax. The TMT is 26 percent
of the excess of petitioner's AMTI over his exemption amount of
$33,750. See sec. 55(b)(1)(A)(i)(I). As petitioner had no items
of tax preference in 1997, AMTI here means petitioner's taxable
income determined with the adjustments provided in section 56.
2There are no factual issues in dispute that are relevant to
ascertaining the tax liability of petitioner in this case and the
Court therefore finds sec. 7491(a) to be inapplicable.
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