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Revenue Code in effect for the year in issue, and all Rule
references are to the Tax Court Rules of Practice and Procedure.
Respondent determined that petitioners are liable for a
deficiency in Federal income tax of $7,364 for the 2003 taxable
year. The issue for decision is whether, in the context of
respondent’s motion for summary judgment, petitioners are liable
for the alternative minimum tax (sometimes referred to as AMT)
for the 2003 taxable year.
Background
At the time the petition was filed petitioners resided in
Concord, California.
Petitioners timely filed a Form 1040, U.S. Individual Income
Tax Return, for the 2003 taxable year (2003 income tax return).
Petitioners reported wages of $323,498. Petitioners claimed
personal exemptions for themselves. Some of petitioners’ claimed
itemized deductions on Schedule A were as follows:
State and local income taxes $39,189
Real estate taxes 4,935
Personal property taxes 230
On line 40 of Form 1040, petitioners reported taxable income of
$270,521, and on line 41 of Form 1040, petitioners reported a tax
of $70,717. Petitioners did not report an AMT on their 2003
income tax return.
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Last modified: May 25, 2011