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the amount of $2,914; (2) State and local income taxes in the
amount of $32,099; and (3) real estate taxes in the amount of
$20,445. On line 41 of Form 1040, petitioners reported taxable
income in the amount of $9,631. Using the 2002 Tax Table,
petitioners reported tax of $963, which they listed on line 55 of
their return. See secs. 1(a)(1), 3(a), (c).
Petitioners neither completed nor attached to their 2002
return Form 6251, Alternative Minimum Tax–Individuals, nor did
they report any liability for the AMT on their return.2
Respondent issued a notice of deficiency to petitioners for
the taxable year 2002. In the notice of deficiency, respondent
did not disallow any of the deductions or exemptions claimed by
petitioners on their Form 1040 for the purpose of the income tax
imposed by section 3(a). See secs. 1(a)(1), 3(c). Rather,
respondent determined that petitioners are liable for the AMT
under section 55 in the amount of $5,328.
2 Typically, AMT would be reported on line 43 of Form 1040.
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