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The issue for decision is whether petitioner is liable for
the alternative minimum tax (AMT) in the amount determined by
respondent.
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. Petitioner resided in
Toledo, Ohio, on the date the petition was filed in this case.
Petitioner filed a Federal income tax return for taxable
year 2000. As is relevant here, petitioner reported on his
return gross income of $1,824 from a refund of taxes; a personal
exemption deduction of $2,800; an itemized deduction of $5,445
for taxes paid; miscellaneous itemized deductions of $27,057 for
unreimbursed employee business expenses; taxable income of
$21,569; and a tax liability of $3,236. Petitioner did not
report AMT liability in any amount. In the notice of deficiency,
respondent did not adjust any of the above items reported by
petitioner. Respondent’s sole adjustment was his determination
that petitioner was liable for the AMT in the amount of $2,301.
We have reviewed respondent’s calculation of the AMT imposed
by section 55(a) and conclude that it is in accordance with the
provisions of the Internal Revenue Code. This calculation, and
the underlying provisions of the Internal Revenue Code, can be
summarized as follows:
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