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Respondent determined a deficiency of $7,267 in petitioner's
2000 Federal income tax.
The sole issue for decision is whether petitioner is liable
for the alternative minimum tax (AMT) under section 55.
Some of the facts were stipulated. Those facts and the
accompanying exhibits are so found and are incorporated herein by
reference. Petitioner's legal residence at the time the petition
was filed was Hot Springs, Virginia.
Petitioner filed a Federal income tax return for 2000
reporting the following gross income items:
Wages and salaries $43,953.68
Taxable interest income 44.14
Dividend income 1,186.75
Taxable refunds 759.43
Taxable IRA distributions 16,714.78
Total income $62,658.78
Petitioner's return included a Schedule A, Itemized Deductions,
in which he claimed itemized deductions for the following:
State and local taxes paid $ 2,115.52
Charitable contributions 200.00
Job expenses and other miscellaneous deductions
(in excess of 2% of adjusted gross income) 59,197.20
Total itemized deductions $61,512.72
After deducting the itemized deductions, petitioner's remaining
income of $1,146.06 was offset by the $2,800 personal exemption.
Thus, petitioner had zero taxable income and no income tax
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