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As we understand the parties’ contentions, it is not
necessary for us to know more of the facts in order to determine
whether or not petitioner is subject to the alternative minimum
tax for 2000. In light of the foregoing and petitioner’s
assertion that he does not dispute the correctness of
respondent’s calculations, we conclude that there is no genuine
issue as to any material fact, within the meaning of Rule 121(b).
Accordingly, we proceed to consider whether a decision may
be rendered as a matter of law.
3. Alternative Minimum Tax
Section 55 imposes a tax--the alternative minimum tax--equal
to the excess (if any) of the tentative minimum tax over the
regular tax.5 Sec. 55(a). Petitioner’s regular tax is zero, and
so his alternative minimum tax is his full tentative minimum tax.
Using Form 6251 (Alternative Minimum Tax--Individuals),
respondent added back petitioner’s appropriate itemized
deductions to the amount by which petitioner’s total itemized
deductions exceeded his adjusted gross income. This operation
resulted in petitioner’s alternative minimum taxable income (sec.
55(b)(2)) being $38,707. From this amount, respondent subtracted
petitioner’s exemption amount. For 2000, in the case of a
married person filing separately, this was $22,500. Sec.
5 For a brief history of the original “minimum tax” and its
eventual replacement by the “alternative minimum tax”, see
Huntsberry v. Commissioner, 83 T.C. 742, 748-752 (1984).
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