- 3 -
records and their return. The representative, who was reading
the figures from records kept in the IRS’s computer database,
explained that she did not have petitioners’ actual return in
that office, and that the reason for the discrepancy was due to
proposed adjustments made by the Commissioner to petitioners’
return. Petitioners replied that they had not previously
received notice of those adjustments, and that the notice of
deficiency was their first indication of a potential change in
their 2002 income tax.
Discussion
Petitioners’ challenge to the proposed deficiency is two-
fold. First, petitioners testified at trial that the alternative
minimum tax should not apply to them because “[lines 1 and 91 of
Form 6251, Alternative Minimum Tax Computation] should be zero”
and not, $397,775, the amount petitioners believe that the IRS
arrived at. Petitioners contend that this discrepancy is just
one example in a string of unexplained discrepancies since their
receipt of the notice of deficiency, and a symptomatic example of
why respondent’s computation should not be afforded credence by
this Court. Second, petitioners maintain that the alternative
minimum tax, as applied to them, is inherently unfair because
1 We believe that petitioners meant to say line 39 on Form
1040.
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Last modified: November 10, 2007