- 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 properPage: Previous 1 2 3 4 5 Next
Last modified: May 25, 2011