Daniel S. and Christi L. Smith - Page 6

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          deduction is allowed for personal exemptions.  Sec. 56(b)(1)(E).            
          The parties part ways in this phase of the computation.                     
               Respondent calculated petitioners’ AMTI as follows:                    
                    Taxable income per return     $147,194                            
                    Personal exemptions           13,200                              
                    State and local taxes paid    16,214                              
                    Unreimbursed employee expenses    30,542                          
                    Sec. 68(a) limitation                                             
                    on itemized deductions        (2,503)                             
                    Taxable State tax refund        (1,544)                           
                    AMTI                          203,103                             

          Respondent’s computation does not take into account the $27,500             
          negative tax preference for intangible drilling costs petitioners           
          claimed on their Form 6251.  Respondent allowed petitioners an              
          exemption under section 55(d)(1) of $35,724, which was based on             
          the $49,000 exemption amount subject to the phaseout reduction of           
          $13,276 (25 percent of the excess of $203,103 over $150,000).               
          Because petitioners’ AMTI of $203,103 exceeded the $35,724                  
          exemption amount by $167,379, petitioners’ tentative minimum tax            
          was computed as 26 percent of the excess, or $43,519.  Because              
          petitioners’ tentative minimum tax of $43,519 exceeds their                 
          regular tax of $34,569, respondent determined that petitioners              
          are liable for AMT of $8,950.                                               












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