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taxes, $4,203 of other taxes, $7,680 of gifts to charity, $13,762
of unreimbursed employee business expenses, $250 of tax
preparation fees, and $1,250 of attorney and accounting fees.
Petitioner calculated his total income tax liability to be
$14,976. Petitioner failed to include any AMT or attach Form
6251, Alternative Minimum Tax--Individuals. After subtracting
$13,137 for Federal income tax withheld and $2,225 for excess
Social Security tax withheld, petitioner requested a refund in
the amount of $386.
On July 12, 2005, respondent issued to petitioner a notice
of deficiency for his 2003 Federal income tax. Respondent
determined a deficiency of $4,176, which was attributable to the
AMT. Petitioner filed a petition seeking redetermination of the
deficiency.
Petitioner has conceded that respondent’s arithmetic in
computing petitioner’s AMT is correct. Petitioner has also
conceded that respondent computed the alternative minimum tax in
accordance with the Internal Revenue Code. Petitioner
nevertheless contends that respondent inappropriately applied the
AMT to his circumstances.
Discussion
Section 55 imposes an AMT in addition to all other taxes
imposed by subtitle A. A taxpayer’s AMT liability is the amount
by which the taxpayer’s tentative tax exceeds his or her regular
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