- 4 - recomputation of taxable income, leading to a new tax base or an alternative minimum taxable income. Sec. 55(b)(2). In making the recomputation, and as relevant herein, certain (but not all) itemized deductions are not allowed, nor is the personal exemption. In particular, section 56(b)(1)(A)(ii) states that no itemized deduction for State and local taxes shall be allowed in computing alternative minimum taxable income. Further, section 56(b)(1)(E) states that no personal exemptions shall be allowed in computing alternative minimum taxable income. Finally, section 56(b)(1)(F) states that section 68 (overall limitation on itemized deductions) does not apply, therefore decreasing taxable income by the amount of the section 68 reduction to itemized deductions. Petitioners do not dispute the computation of the AMT as determined by respondent. Petitioners nevertheless contend that the AMT is confusing and complex, and they are unclear as to why they are liable for the AMT, which effectively deprives them of the benefit of some itemized deductions. Petitioners also make reference to recent proposals by Congress to repeal or modify the AMT and criticism of the AMT by the National Taxpayer Advocate. Congress established the alternative minimum taxable income as a broad base of income in order to tax taxpayers more closely on their economic income, intending for all taxpayers to pay their fair share of the overall Federal income tax burden. AllenPage: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011