- 3 - liability. He claimed a refund of $10,345.41 in Federal income tax withholdings. Respondent made no adjustments to either the income or the itemized deductions on petitioner's return. Petitioner did not include with his return the necessary form for computation of the AMT under section 55. After he was contacted by respondent, petitioner submitted to the Internal Revenue Service (IRS) Form 6251, Alternative Minimum Tax–-Individuals, which reflected an AMT of $7,266.83. Petitioner made no payments to the IRS of the AMT, although he paid $1,826.54 as additional tax under section 72(t) for his early withdrawal during 2000 of a qualified pension plan. In the notice of deficiency, respondent determined that petitioner was liable for the AMT in the amount of $7,267. No other determinations were made with regard to petitioner's 2000 Federal income tax return. Petitioner's principal argument is that, if he is held liable for the AMT, that liability effectively negates or eliminates the tax benefits of his itemized deductions. Petitioner further argues that, if he is liable for the AMT, the accrued interest of $510.44 on the deficiency should be abated because the deficiency is one he did not know existed at the time he filed his return. Section 55(a) imposes a tax equal to the excess of the tentative minimum tax over the regular tax. The tentativePage: Previous 1 2 3 4 5 6 7 8 Next
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