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entered is not reviewable by any other court, and this opinion
should not be cited as authority.
Respondent determined a deficiency of $8,950 in petitioners’
2002 Federal income tax. The deficiency results entirely from
the imposition of the section 55 alternative minimum tax (AMT).
The issue for decision is whether in the computation of their
AMT liability petitioners are entitled to take into account a
negative tax preference item.
Background
All of the facts in this case submitted under Rule 122 have
been stipulated and are so found. At the time the petition was
filed, petitioners resided in Pocatello, Idaho.
Daniel Smith was employed as a medical sales representative,
and Christi Smith was not employed during 2002.
Petitioners filed a timely 2002 joint Federal income tax
return. On that return they reported adjusted gross income of
$220,739 (amounts are rounded to the nearest dollar) that
consists, in part, of wage income of $216,419 and refunds of
State and local taxes of $1,544.
Petitioners’ return includes a Schedule A, Itemized
Deductions, on which petitioners claimed itemized deductions as
follows:
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