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wished refunded. On December 9, 2002, respondent issued the full
refund to petitioner.
In the notice of deficiency, respondent’s only adjustment to
income was the allowance of $225 of previously unclaimed Other
Interest Expense.4 Respondent agrees that petitioner’s “regular
tax” (see sec. 55(c)) is zero.
Discussion
1. Parties’ Contentions
Petitioner contends that the purpose of the alternative
minimum tax provisions is to prevent high-income taxpayers from
escaping all income tax liability by using exclusions,
deductions, and credits. He maintains that “Obviously, the
Petitioner did not have a significant level of economic income
and all of his deductions and exemptions were deemed legitimate
by the Respondent.” Petitioner concludes that the “Congress did
not intend the AMT to apply at [sic] low or middle-income
taxpayers like the Petitioner.”
Respondent contends that the statute subjects petitioner to
the alternative minimum tax and that the legislative history does
not leave room for any interpretation of the statute that would
4 Because respondent rounded many items, this resulted in
reducing petitioner’s alternative minimum taxable income by
$223.35. Cf. Christman v. Commissioner, T.C. Memo. 1989-259,
(additional itemized deduction increased the taxpayer’s
alternative minimum taxable income under the statute as in effect
for 1980).
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