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petitioner completed the Form 6251 and submitted a copy to
respondent.
In computing his alternative minimum taxable income (AMTI)
on Form 6251, petitioner made the following three adjustments:
(1) He increased the AMTI amount by the $9,250.10 of taxes paid
during the year; (2) he increased the AMTI amount by $578.08 for
tax-exempt interest from private activity bonds issued after
August 7, 1986; and (3) he decreased the AMTI amount by the
$7,400.08 that represents the amount by which his otherwise
allowable itemized deductions would have been limited had he
elected to itemize his deductions for regular tax purposes.
Petitioner made no adjustment to his AMTI for the $4,300 standard
deduction he actually deducted on Form 1040. On the basis of his
above adjustments in arriving at AMTI, petitioner determined that
he owed no AMT for 1999.
Upon reviewing petitioner’s Form 6251, respondent disallowed
petitioner’s adjustments to AMTI for the itemized deductions that
were not used in computing regular taxable income. Respondent’s
position is that taxpayers who claim the standard deduction for
regular tax purposes may not use itemized deductions for AMT
purposes.
Respondent recomputed petitioner’s AMTI by making an
increasing adjustment for the $4,300 standard deduction claimed
on petitioner’s Form 1040. Respondent made no corresponding
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