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farm property. Since petitioners apparently did not purchase
another residence within 12 months, they were required to report
and accordingly, pay tax on, the proceeds from the sale as long
term capital gain. While we sympathize with the fact that
petitioners are middle-income taxpayers who, without the proceeds
of sale, would not otherwise be subject to the alternative
minimum tax, we cannot change the facts, nor the statute, to
provide them with equitable relief. The triggering event in this
case was a one-time sale, making petitioners subject to the
alternative minimum tax. It is simply beyond the purview of this
Court to decide otherwise.
We also remind petitioners that this Court has consistently
and repeatedly rejected challenges to proposed deficiencies based
on the fairness of the alternative minimum tax. Kenseth v.
Commissioner, 259 F.3d 881 (7th Cir. 2001), affg. 114 T.C. 399
(2000); Merlo v. Commissioner, 126 T.C. 205 (2006); see also
Alexander v. IRS, 72 F.3d 938 (1st Cir. 1995), affg. T.C. Memo.
1995-51; Okin v. Commissioner, 808 F.2d 1338 (9th Cir. 1987),
affg. T.C. Memo. 1985-199; Warfield v. Commissioner, 84 T.C. 179
(1985); Huntsberry v. Commissioner, 83 T.C. 742 (1984).
Accordingly, we sustain respondent’s proposed deficiency.
Finally, as to the issue of interest, petitioner did not
either formally request an abatement of the interest on the
liability at issue as required under section 6404(e), nor did he
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