-5- 2001. Petitioners calculated their 2001 AMTI on 2001 Form 6251, Alternative Minimum Tax--Individuals, by reporting a negative $1,929,509 adjustment on line 9 of that form and by reporting two other unrelated adjustments in the total amount of $5,999.4 They reported that their AMTI was negative $1,362,349 (taxable income of $561,161 + negative $1,929,509 + $5,999) and that their 2001 tentative minimum tax and 2001 AMT were both zero. For 2000, petitioners’ AMT equaled $588,066. Petitioners adjusted that amount by $46,553 to reflect a net minimum tax on exclusion items and claimed on their 2001 return that they had a $541,513 minimum tax credit that could be applied to 2001 and later years. Petitioners applied $191,457 of this credit to their 2001 regular tax liability of $191,457, thus reducing that liability to zero, and claimed the $350,056 balance as a minimum tax carryover to 2002. Respondent determined that petitioners were not entitled to the negative $1,929,509 adjustment. Accordingly, respondent determined, petitioners’ 2001 AMTI was $567,160 (negative $1,362,349 + $1,929,509) and their resulting 2001 tentative minimum tax was $155,305. Further, respondent determined, 4 We are unsure of the specifics of the negative $1,929,509 adjustment. Petitioners claim in their posttrial brief that they are entitled to a negative adjustment of $2,086,009, or in other words, the difference (as rounded) between the 2001 regular tax capital gain of $148,461 and the 2001 AMT capital loss of $1,937,547.Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
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