-5-
an issue at trial. In their computation, petitioners point out
that alternative minimum tax of $1,553 was reported on their
return for 2002, but no alternative minimum tax was determined
“per exam”. In effect, petitioners’ computation suggests that
alternative minimum tax is not applicable because none was
computed in the notice of deficiency.
We disagree. There is nothing in the record to suggest that
respondent conceded the alternative minimum tax in this case, and
petitioners have shown no reason why the alternative minimum tax
is not applicable. No alternative minimum tax was determined by
respondent in the notice of deficiency because there was no
excess of tentative minimum tax over regular tax, based upon the
adjustments determined in the notice of deficiency. See sec.
55(a). Based upon the adjustments redetermined in these
proceedings, the situation is different. This is simply a
computational matter. We agree with respondent that alternative
minimum tax is applicable, and we agree with the amount computed
in respondent’s revised computation, $1,688.
Item No. 5: Petitioners claim a child tax credit of $500,
the same amount claimed on their return, whereas respondent’s
revised computation allows zero. Respondent disallowed the child
tax credit in the notice of deficiency as a result of the
application of the limitation based on petitioners’ adjusted
gross income. See sec. 24(b)(1). Similarly, based upon the
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