- 6 - 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...)Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
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