Lawrence Moore - Page 7

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          56(b) are threefold.  First, section 56(b)(1)(A)(i) provides that           
          no deduction shall be allowed for "any miscellaneous itemized               
          deduction (as defined in section 67(b))".  Second, section                  
          56(b)(1)(A)(ii) states that no itemized deduction for State and             
          local taxes shall be allowed in computing alternative minimum               
          taxable income.  Third, section 56(b)(1)(E) states that no                  
          personal exemptions shall be allowed in computing AMTI.                     
               The effect of section 56(b)(1)(A)(i), (ii), and (b)(1)(E) is           
          to increase petitioner's taxable income amount by:  (1) $39,224,            
          the amount claimed on petitioner's Schedule A as miscellaneous              
          deductions for unreimbursed employee expenses; (2) $4,999, the              
          amount claimed on petitioner's Schedule A for State and local               
          taxes; and (3) $2,750, the amount claimed on petitioner's Form              
          1040 for a personal exemption.                                              
               After taking into account the foregoing three adjustments,             
          petitioner's AMTI for 1999 is $54,719.  Petitioner's AMTI exceeds           
          the applicable exemption amount of $33,750 by $20,969.  See sec.            
          55(d)(1)(A)(i).  Petitioner's tentative minimum tax is therefore            
          26 percent of that excess, or $5,452.  See sec.                             
          55(b)(1)(A)(i)(I).  Because petitioner's TMT exceeds petitioner's           
          regular tax of $1,219, petitioner is liable for the alternative             
          minimum tax in the amount of such excess, $5,452 less $1,219, or            

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