-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.
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