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income tax for 1999 of $439.45. The sole issue for decision is
whether petitioner is subject to the alternative minimum tax
(AMT).
Some of the facts in this case have been stipulated and are
so found. The stipulation of facts and the attached exhibits are
incorporated herein by this reference. At the time the petition
was filed, petitioner lived in Los Angeles, California.
During 1999, petitioner was employed by Sun Microsystems,
Inc., as a programmer. On his timely filed Form 1040, U.S.
Individual Income Tax Return for 1999, petitioner reported the
following items of income:
Line Amount
7 Wages $117,515.82
8a Taxable interest 3,501.76
9 Ordinary dividends 1,273.40
13 Capital gain 893,468.96
22 Total income $1,015,759.94
33 Adjusted gross income $1,015,759.94
In preparing his 1999 tax return, petitioner correctly
claimed no deduction for a personal exemption because the
exemption amount was completely phased out pursuant to section
151(d). In further preparing his return, petitioner determined
that he incurred the following amounts for taxes paid during 1999
that qualified as itemized deductions pursuant to section 164(a):
State and local income taxes $9,153.10
Personal property taxes 97.00
Total itemized deductions $9,250.10
Since petitioner’s adjusted gross income for 1999 exceeded
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