- 6 - Petitioners reduced their AMTI by the $27,500 negative tax preference item.1 Otherwise, petitioners computed the $12 AMT liability reported on the Form 6251 in a manner consistent with respondent’s computation. We are aware of no authority that allows taxpayers to reduce AMTI as petitioners have, and we find that respondent properly computed petitioners’ AMT liability. Accordingly, respondent’s determination in that regard is sustained. Reviewed and adopted as the report of the Small Tax Case Division. To reflect the foregoing, Decision will be entered for respondent. 1 Sec. 59(e) allows a taxpayer to make an election to deduct qualified expenditures for intangible drilling costs ratably over a 60-month period. If this election is made with respect to any qualified expenditure, then that amount is not treated as a tax preference item under sec. 57, and sec. 56 does not apply. Sec. 59(e)(6). We note, however, that an election under sec. 59(e) does not result in the qualified expenditure’s being deducted from AMTI as a negative tax preference. In any event, the record does not establish that petitioners made an election under sec. 59(e), and no evidence has been introduced regarding the source of the negative tax preference item.Page: Previous 1 2 3 4 5 6 7
Last modified: May 25, 2011