-6-
petitioners had no 2001 net minimum tax on exclusion items and a
$588,066 minimum tax credit ($541,513 + $46,553) that was
available for 2001 and later years. Respondent determined that
petitioners could apply $36,152 of that credit to 2001 (regular
tax liability of $191,457 - 2001 tentative minimum tax of
$155,305) and carry over the $551,914 balance to later years.
Discussion
The Internal Revenue Code imposes upon taxpayers an AMT in
addition to all other taxes imposed by subtitle A. See sec.
55(a); Allen v. Commissioner, 118 T.C. 1, 5 (2002). The AMT is
imposed upon a taxpayer’s AMTI, which is an income base broader
than the usual base of taxable income applicable to Federal
income taxes in general. See Allen v. Commissioner, supra at 5.
In order to compute AMTI, an individual must first compute his or
her taxable income and then alter that amount (by way of an
adjustment or an increase) to reflect the items described in the
remainder of part VI, subchapter A, chapter 1, subtitle A (part
VI).5 Id. at 10.
5 Part VI includes five sections, numbered and titled as
follows:
SEC. 55. Alternative Minimum Tax Imposed;
SEC. 56. Adjustments in Computing Alternative Minimum
Taxable Income;
SEC. 57. Items of Tax Preference;
SEC. 58. Denial of Certain Losses; and
SEC. 59. Other Definitions and Special Rules.
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