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and boat depreciation of $8,776.1 Petitioner did not report
liability for the AMT in any amount. In the notice of
deficiency, respondent’s sole adjustment was his determination
that petitioner was liable for AMT of $3,815. Respondent did not
adjust any of petitioner’s claimed itemized deductions, nor did
respondent determine that any additions to tax or penalties were
applicable.
The first issue for decision is whether petitioner is liable
for the AMT in the amount determined by respondent. Petitioner
argues that respondent’s calculation of the AMT is in error, but
he does not single out any specific aspect of that calculation.
We have reviewed respondent’s calculation and conclude that it is
in accordance with the provisions of the Internal Revenue Code.
This calculation, and the underlying provisions of the Code, can
be summarized as follows:
Taxable income reported by petitioner $10,151
Miscellaneous itemized deductions claimed by petitioner 36,773
Itemized deduction for taxes paid claimed by petitioner 4,617
Exemption deduction claimed by petitioner 2,750
Alternative minimum taxable income under sec. 55(b)(2)154,291
Exemption amount pursuant to sec. 55(d)(1)(B) (33,750)
Taxable excess under sec. 55(b)(1)(A)(ii) 20,541
Tentative minimum tax under sec. 55(b)(1)(A)(i) (in this
case equal to 26% of the taxable excess) 5,341
Regular tax under sec. 55(c)(1) as reported by petitioner (1,526)
AMT liability under sec. 55(a) 3,815
1The adjustments to taxable income required in this case to
calculate alternative minimum taxable income are found, respectively, in
sec. 56(b)(1)(A)(i) and (ii) and (E).
1The deductions for the employee business expenses and tax
preparation fees were reduced by $1,389 pursuant to the sec.
67(a) floor on miscellaneous itemized deductions.
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