Arthur O. & Wanda E. Trevino - Page 4




                                        - 3 -                                         
               Tentative minimum tax                                          2,483   
               Regular tax                                                      -0-   
               Section 55(a) AMT liability                                    2,483   
                    1The amount listed here as taxable income reflects a computational
               adjustment made to the amount of taxable income reported on petitioners’
               return:  Petitioners did not apply the itemized deduction limitation of
               sec. 68(a), which requires a subtraction of $897 from their claimed    
               itemized deductions.                                                   
               Petitioners contend that their tax liability “was                      
          intentionally miscalculated” by the IRS.  However, as we noted,             
          respondent’s calculation of petitioners’ tax liability is in                
          accordance with the law.  Petitioners further state that the                
          “issue here is about prejudice and harassment to Puerto Rican               
          taxpayers,” and petitioners question the general treatment of               
          residents of Puerto Rico under the Internal Revenue Code.  This             
          Court is not the proper place for these arguments.  We cannot               
          evaluate the fairness of the law but must apply it as it is                 
          written; it is up to Congress to address questions of fairness              
          and to make improvements to the law.  Metzger Trust v.                      
          Commissioner, 76 T.C. 42, 59-60 (1981), affd. 693 F.2d 459 (5th             
          Cir. 1982).                                                                 
               Petitioners do contest two specific aspects of the AMT                 
          calculation.  First, they dispute the treatment of the itemized             
          deduction they claimed on their return for mortgage interest.               
          This treatment is in fact beneficial to petitioners.  Petitioners           
          had listed this deduction as an adjustment on the Form 6251,                
          Alternative Minimum Tax--Individuals, which they filed with their           
          return.  Respondent determined that this was not a proper                   






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