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not allowed in the computation of alternative minimum taxable
income. Sec. 56(b)(1)(A)(i). The sum of these disallowed items
will trigger a liability for the AMT. In petitioner's situation,
his unreimbursed employee expenses alone total $60,445.32
(compared to his reported wage income of $43,953.68). Coupled
with the other unallowable expenses, specifically spelled out in
the statute, petitioner's AMT liability ensues. The AMT serves
to impose a tax whenever the sum of specified percentages of the
excess of alternative minimum taxable income over the applicable
exemption amount exceeds the regular tax for that year. Sec.
55(a), (b)(1)(A), (C), (d)(1); Huntsberry v. Commissioner, 83
T.C. 742 (1984). However unfair this statute might seem to
petitioner, the Court must apply the law as written. As this
Court noted in Hays Corp. v. Commissioner, 40 T.C. 436, 443
(1963), affd. 331 F.2d 422 (7th Cir. 1964): "The proper place
for a consideration of petitioner's complaint is the halls of
Congress, not here." Respondent, therefore, is sustained on this
issue.
Petitioner argues that he should not be liable for interest
on the deficiency, in effect, seeking an abatement of interest.
When petitioner filed his return, he reported a zero tax
liability and claimed a refund of $10,349.41 from tax
withholdings. He argues that he should not be liable for
interest on tax he did not know that he owed.
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