- 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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Last modified: May 25, 2011