- 10 - 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 otherwisePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011