David M. Marx - Page 5




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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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