Chad W. and Aliza Kold-Warren - Page 5
Item No. 2: Petitioners’ computation claims miscellaneous
deductions, subject to the 2-percent of adjusted gross income
limitation, of $18,191, whereas respondent’s revised computation
allows a higher amount, $18,360, a difference of $169. The
amount allowed by respondent is the sum of $16,672, and $1,688.
These amounts are set forth in paragraphs 6 and 7 of the
Stipulation of Facts, respectively. They relate to deductions
for depreciation and other automobile expenses for the
unreimbursed employee business use of petitioners’ truck.
Accordingly, the miscellaneous deductions, subject to the 2-
percent of adjusted gross income limitation, allowed in
respondent’s revised computation, $18,360, is correct.
Item No. 3: Petitioners’ computation calculates tax of
$8,439, based upon taxable income of $59,421.52, whereas
respondent’s revised computation calculates tax of $9,827, based
upon taxable income of $59,384. The tax computed by respondent
is $1,388 more than the tax computed by petitioners.
Respondent’s tax computation, based upon the tax table for
married individuals filing joint returns, is correct, i.e.,
(($59,384-$46,700) x .27) +$6,405.
Item No. 4: Petitioners compute no alternative minimum tax,
whereas respondent’s revised computation computes alternative
minimum tax of $1,688. The alternative minimum tax is not
mentioned in the Stipulation of Facts, and it was not raised as
Page: 1 2 3 4 5 6 7 8
Last modified: March 27, 2008