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application of the AMT to petitioner’s facts produces an absurd
result. Presumably petitioner believes regulations could be
written to ameliorate such result.
It is not very clear what kind of regulation petitioner
would like to have written even if we were in position to do so.
Be that as it may, and to paraphrase the words of the Fourth
Circuit in Hillman v. IRS, supra at 234, if there is an inequity
in the AMT as applied to petitioner, only Congress or the
Secretary (as the holder of delegated authority from Congress to
modify the effects of the AMT in certain instances) has the
authority to ameliorate the inequity.
Since our Opinion in Speltz v. Commissioner, 124 T.C. 165
(2005), contains a detailed analysis of “promotion of effective
tax administration” as a ground for the compromise of a
liability, and the analysis is equally applicable to the facts in
this case, it is unnecessary for us to repeat this extensive
analysis here. Thus, this case is controlled by the result in
Speltz.
As did the taxpayers in Speltz, petitioner has devoted a
substantial part of her argument to the perceived unfairness of
the AMT as applied to her specific facts. The crux of
petitioner’s position, as in Speltz, appears to be that section
7122 trumps the literal application of the AMT statutes, and
that, therefore, it was an abuse of discretion by the Appeals
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