David M. Marx - Page 11




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          purposes must recompute those itemized deductions for AMT                   
          purposes without regard to the section 68 limitation.  For                  
          section 56(b)(1)(F) to apply at all, the taxpayer must have                 
          elected to itemize deductions for regular tax purposes and had              
          those deductions reduced pursuant to section 68.  Petitioner’s              
          interpretation goes well beyond the limited application of                  
          section 56(b)(1)(F).                                                        
               To interpret section 56(b)(1)(F) alone without giving full             
          effect to all the provisions of section 56(b) renders section               
          56(b)(1)(E) inoperative.  Petitioner’s argument is a narrow                 
          interpretation that overlooks section 56(b)(1)(E).  By strictly             
          isolating section 56(b)(1)(F), petitioner is attempting to change           
          the meaning of the statute as a whole.  The only way petitioner’s           
          argument would have validity would be if section 56(b) contained            
          a provision allowing the taxpayer to pick and choose which                  
          adjustments were most favorable to his particular tax situation             
          or a provision allowing for adjustments for itemized deductions             
          that were not deducted for regular tax purposes because the                 
          standard deduction was claimed.  However, no such provisions                
          exist in the Code.  When read as a whole, section 56(b) requires            
          the taxpayer to make adjustments for AMT purposes in a manner               
          consistent with decisions made for regular tax purposes.                    
          Accordingly, petitioner’s argument that section 56(b)(1)(F)                 
          allows him to compute AMTI using the full value of his otherwise            






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