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to be entered is not reviewable by any other court, and this
opinion shall not be treated as precedent for any other case.
Respondent determined a deficiency of $1,355.44 in
petitioners’ 2004 Federal income tax. After concessions by
petitioners,2 this Court must decide the extent of petitioners’
alternative minimum tax (AMT) liability.
Background
Petitioners filed a joint Federal income tax return for
2004, in which they reported $101,765 in estimated income tax
payments and $4,176.49 of income tax withheld. Petitioners
calculated that they were due a $6,141.73 refund. Upon receipt
of the return, respondent reduced petitioners’ claimed educator
expense deductions by $213 and assessed the resulting additional
tax of $67.80 as a mathematical error.3 Respondent also assessed
and imposed a section 6654(a) addition to tax of $878.08 for
failure to pay estimated income tax. As a result, respondent
reduced petitioners’ refund from $6,141.73 to $5,195.85, a
2 At trial, petitioners conceded that they are liable for
the alternative minimum tax (AMT), but they maintain that they
are liable for only $404, rather than the $1,352 determined by
respondent. Petitioners also concede a $9 mathematical error
that effectively reduces petitioners’ Schedule A, Itemized
Deductions.
3 Petitioners claimed a $713 educator expense deduction.
Sec. 62(a)(2)(D) limits educator expenses to $250 per eligible
educator, thus limiting petitioners’ eligibility for such a
deduction to $500. In accordance with sec. 6213(b)(1) and
(g)(2)(E)(i), respondent properly reduced as a mathematical error
the $213 excess claimed.
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Last modified: November 10, 2007