Chad W. and Aliza Kold-Warren - Page 5




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               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             







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