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v. Commissioner, T.C. Memo. 1997-379, affd. 164 F.3d 629 (9th
Cir. 1998). Respondent’s allowance of certain itemized
deductions in 1999 does not establish petitioners’ entitlement to
similar deductions in 2000.
For the above-stated reasons and to reflect respondent’s
concessions, we find that petitioners are entitled to itemized
deductions of $243,363 and miscellaneous itemized deductions of
$84,581.
V. Alternative Minimum Tax
In the notice of deficiency, respondent determined that
petitioners were liable for alternative minimum tax of $314,371.
Petitioners’ alternative minimum tax liability was triggered in
part by the itemized deductions claimed on their Federal income
tax return. Respondent concedes that, if petitioners are
entitled to itemized deductions and miscellaneous itemized
deductions only to the extent conceded by respondent, the
alternative minimum tax will not apply. As found above,
petitioners are entitled to itemized deductions and miscellaneous
itemized deductions only to the extent conceded by respondent.
Therefore, a determination regarding petitioners’ alternative
minimum tax liability is unnecessary.
VI. Section 6651(a)(1) Addition to Tax
Section 6651(a)(1) imposes an addition to tax for failure to
file a return on the date prescribed (in this case, April 16,
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