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minimum tax for noncorporate taxpayers is equal to 26 percent of
so much of the taxable excess as does not exceed $175,000. Sec.
55(b)(1)(A)(i). The taxable excess is that amount by which the
alternative minimum taxable income (AMTI) exceeds the exemption
amount. Sec. 55(b)(1)(A)(ii). The exemption amount for
individuals filing singly, as in petitioner's case, is $33,750.
Sec. 55(d).
AMTI equals the taxpayer's taxable income for the year
determined with the adjustments provided in section 56. Sec.
55(b)(2). In calculating AMTI, no deduction is allowed for
miscellaneous itemized deductions or for State and local taxes
paid, unless such amounts are deductible in determining adjusted
gross income. Sec. 56(b)(1). Also, no deduction for the
personal exemption under section 151 is allowed. Sec.
56(b)(1)(E). Petitioner presented no evidence that the AMT was
incorrectly calculated. His sole argument, noted above, is that
the AMT effectively deprives him of the benefit of his itemized
deductions, all of which were accepted by respondent.
The determination of a taxpayer's AMT requires a
recomputation of taxable income, leading to a new tax base,
alternative minimum taxable income. Sec. 55(b)(2). In making
the recomputation, certain (but not all) itemized deductions are
not allowed, as well as the personal exemption. In particular,
as relates to petitioner, miscellaneous itemized deductions are
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