Estate of Clifford C. Haugen - Page 7

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          1998 return totaling $315,587.  Petitioners agreed to those                 
          adjustments but consented only to an assessment of additional tax           
          of $23,360, based on the same income-averaging amounts on                   
          Schedule J of the original return, without any adjustment for the           
          NOLs for 1995 and 1996 that had been carried back to earlier                
          years.  Respondent did not agree or consent to that computation             
          method using the negative income amounts of the 1995 and 1996               
          base years.                                                                 
               Likewise, petitioner's 1999 income tax return was examined             
          by the IRS, and petitioner agreed to an assessment of additional            
          tax on income adjustments totaling $71,847.  Petitioner's consent           
          to this assessment was also based on income averaging and                   
          utilization of the same NOL for 1996 without any adjustment for             
          the carryback of the 1996 NOL to 1993.  Respondent likewise did             
          not agree or consent to this computation method.  See supra note            
          3.                                                                          
               The second issue is petitioners' disagreement over                     
          respondent's computation of the alternative minimum tax of $4,545           
          for 1998 under section 55.7  Petitioner contends that where the             


               7    As noted earlier, petitioner agreed to an AMT                     
          assessment of $30,087 for 1998 pursuant to agreed income                    
          adjustments but on a computation of tax under sec. 1301 without             
          any adjustments to the negative taxable income for 2 of the base            
          years in the income-averaging computation.  The $4,545 AMT                  
          determination for 1998 is based on the same income adjustments              
          agreed to by petitioner but with a tax computed under sec. 1301             
                                                             (continued...)           





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