Helen Guterman - Page 4

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          housing corporation is an adjustment for purposes of computing              
          the AMT.  Thus, respondent recalculated and increased                       
          petitioner’s AMT in the amount of $4,255.                                   
               Section 216 allows a tenant-stockholder to deduct amounts              
          (not otherwise deductible) paid or accrued to a cooperative                 
          housing corporation within the taxable year, to the extent that             
          such amounts represent the tenant-stockholder’s proportionate               
          share of the real estate taxes allowable as a deduction to the              
          corporation under section 164.  Sec. 216(a)(1); sec. 1.216-                 
          1(a)(1), Income Tax Regs.  Section 164 allows a deduction for               
          real property taxes paid or accrued within the taxable year.                
          Sec. 164(a)(1); sec. 1.164-1(a)(1), Income Tax Regs.                        
               Section 55 imposes an alternative minimum tax (AMT) on                 
          taxpayers, in addition to any other income tax imposed.  An                 
          individual’s AMT is determined by a recomputation of the                    
          individual’s taxable income, which results in a new tax base, the           
          AMT income.  Sec. 55(b)(2).  In determining the AMT income,                 
          certain adjustments are required and no deduction is allowed for            
          any miscellaneous itemized deduction (as defined in section                 
          67(b)), or for any taxes described in section 164(1), (2), or               
          (3), except for a non-pertinent exception.  Sec. 56(b)(1)(A).               
               We have held previously that the text of the AMT statute is            
          unambiguous.  Klaassen v. Commissioner, T.C. Memo. 1998-241,                
          affd. without published opinion 182 F.3d 932 (10th Cir. 1999).              

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