- 3 - petitioners treated the $10,489 as deductible in computing their alternative minimum taxable income. OPINION A. Background Section 164 provides a deduction for real property taxes and other specified taxes paid or accrued by the taxpayer during the taxable year. Sec. 164(a)(1).2 In addition, a tenant- stockholder may deduct amounts paid by or accrued to a cooperative housing corporation within the taxable year, to the extent that the amounts represent the tenant-stockholder's proportionate share of (1) the real estate taxes deductible by the corporation under section 164, sec. 216(a)(1), and (2) the mortgage interest deductible by the corporation under section 163, sec. 216(a)(2).3 2 Sec. 164(a) provides in pertinent part: SEC. 164. TAXES. (a) General Rule.--Except as otherwise provided in this section, the following taxes shall be allowed as a deduction for the taxable year within which paid or accrued: (1) State and local, and foreign, real property taxes. (2) State and local personal property taxes. (3) State and local, and foreign, income, war profits, and excess profits taxes. 3 Sec. 216 provides in pertinent part: (continued...)Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
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