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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 tentative
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