Jonathan N. and Kimberly A. Palahnuk - Page 6

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          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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