- 3 -
respondent summarily assessed $80,330 of tax on this “corrected”
taxable income, after making the “math error” adjustments and
associated mathematical adjustments.3 Using this same
“corrected” taxable income, respondent also recomputed
petitioner’s alternative minimum tax. By statutory notice of
deficiency, respondent determined that petitioners had a
resulting deficiency of $6,073 (apart from the tax that
respondent had summarily assessed pursuant to section 6213(b)).
Discussion
Petitioners contend that they correctly reported their
qualified dividends on their 2005 Form 1040 and correctly
calculated and paid tax on those qualified dividends at the rate
of 15 percent.4 Petitioners contend that respondent erred in
determining that the qualified dividends should be included in
the calculation of their alternative minimum tax.
2(...continued)
petitioners conceded these two other math errors.
3 Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the year at issue.
4 In summarily assessing petitioners’ tax on their
“corrected” taxable income, respondent also computed tax on the
qualified dividends at 15 percent and credited petitioners with
the 15-percent tax they had separately reported on line 45. In
this proceeding, petitioners do not challenge the summary
assessment, which is beyond the scope of our jurisdiction. See
sec. 6213(b)(1); Meyer v. Commissioner, 97 T.C. 555, 559-560
(1991).
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Last modified: March 27, 2008