- 6 -
itemized deductions on the amended return, he has not presented
any evidence to substantiate that he is entitled to these
additional deductions. Instead, petitioner contends that the
total itemized deductions should not be limited when he
accurately answered the following question on line 28 of Schedule
A: “Is Form 1040, line 34, over $128,950 (over $64,475 if
married filing separately)?” This limitation, however, is based
upon section 68 and not upon section 67, the latter of which, as
indicated earlier, is the basis of respondent’s determination.
We conclude that petitioner is entitled to claim total
itemized deductions of $34,638 for the 2000 taxable year, an
amount $243 less than $34,881 claimed on the 2000 income tax
return. Accordingly, we sustain respondent’s determination with
respect to this issue.
Alternative Minimum Tax
Respondent determined that petitioner is liable for an AMT
of $4,802 for the 2000 taxable year. Section 55 imposes, in
addition to all other taxes imposed by subtitle A, an AMT on
noncorporate taxpayers. The determination of a noncorporate
taxpayer’s AMT requires a recomputation of taxable income,
leading to a new tax base or an alternative minimum taxable
income. Sec. 55(b)(2). In making the recomputation, certain
(but not all) itemized deductions are not allowed, nor is the
personal exemption. In particular, miscellaneous itemized
Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011