Legal Opinion

Sparrow v. Commissioner

United States Tax Court

Decided May 5, 1986No. Docket No. 17238-83PublishedCited by 8 opinions

Ps were qualified to, and elected to, use the income averaging provisions (secs. 1301- 1305, I.R.C. 1954) to reduce their tax under sec. 1 for the year 1980. However, in determining whether or not they were liable for the alternative minimum tax under sec. 55, I.R.C. 1954, Ps used as their "regular tax" a higher tax figure computed under sec. 1 without income averaging.

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Ps were qualified to, and elected to, use the income averaging provisions (secs. 1301- 1305, I.R.C. 1954) to reduce their tax under sec. 1 for the year 1980. However, in determining whether or not they were liable for the alternative minimum tax under sec. 55, I.R.C. 1954, Ps used as their "regular tax" a higher tax figure computed under sec. 1 without income averaging. Held, Ps' "regular tax" for purposes of determining their liability for the alternative minimum tax under sec. 55 is their sec. 1 tax computed under the income averaging provisions.

1Opinion of the Court

PARKER, Judge-.

Respondent determined a deficiency in petitioners’ 1980 Federal income taxes in the amount of $1,865.25. The sole issue involves the proper figure to be used as “regular tax” in determining whether or not petitioners Eire hable for the alternative minimum tax under section 55.1

FINDINGS OF FACT

This case was submitted fully stipulated. The stipulation of facts and the exhibits attached thereto are incorporated herein by this reference.

Petitioners, husband and wife, resided in Winston-Salem, North Carolina, at the time they filed their petition in this case. They timely filed…

2Cases cited5 opinions

  1. Badaracco v. CommissionerSupreme Court of the United States · 1984
  2. Greenberg's Express, Inc. v. CommissionerUnited States Tax Court · 1974
  3. Huntsberry v. CommissionerUnited States Tax Court · 1984
  4. Warfield v. CommissionerUnited States Tax Court · 1985
  5. Okin v. CommissionerUnited States Tax Court · 1985

3Cited by8 opinions

  1. Levin v. CommissionerUnited States Tax Court · 1986
  2. Norwest Corp. v. Comm'rUnited States Tax Court · 1998
  3. DeCleene v. CommissionerUnited States Tax Court · 2000
  4. ESTATE OF CLIFFORD C. HAUGEN v. COMMISSIONERUnited States Tax Court · 2004
  5. Levin v. CommissionerUnited States Tax Court · 1986

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