- 2 - Respondent determined a deficiency in petitioners’ Federal income tax of $2,483 for the taxable year 1998. The issue for decision is whether and to what extent petitioners are liable for the alternative minimum tax (AMT). Some of the facts have been stipulated and are so found. The stipulations of fact and the attached exhibits are incorporated herein by this reference. Petitioners resided in Mayaguez, Puerto Rico, on the date the petition was filed in this case. There are no disputed facts in this case. During 1998, petitioners’ primary sources of income were petitioner husband’s Federal government salary of $56,746 and a distribution from his Federal retirement account of $97,796. Petitioners filed a joint Federal income tax return for taxable year 1998. On that return they reported a foreign tax credit of $34,616 and zero tax liability. They also reported zero liability for the AMT. In the statutory notice of deficiency, respondent determined that petitioners are liable for the AMT in the amount of $2,483. This is in accord with our calculation under section 55(a), which is as follows: Taxable income reported by petitioners1 $129,603 Exemption deductions claimed by petitioners 10,800 Itemized deduction claimed by petitioners for taxes paid 999 Amount of section 68(a) limitation on itemized deductions (897) Alternative minimum taxable income 140,505 Exemption amount (45,000) Taxable excess 95,505 Pre-credit tentative minimum tax (26% of taxable excess) 24,831 AMT foreign tax credit (limited to 90% of $24,831) (22,348)Page: Previous 1 2 3 4 5 Next
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