McCarthy Trust v. Commissioner
United States Tax Court
During the taxable year 1979, the amount of petitioner's interest income exceeded the amount of its interest expense. Held, petitioner's adjusted itemized deductions in determining its alternative minimum taxable income for purposes of the alternative minimum tax include the amount of interest expense deducted without offset for interest income.
1Opinion of the Court
JACOBS, Judge:
Respondent determined a deficiency in petitioner’s 1979 Federal income tax in the amount of SIO^OG.1 The issue for decision concerns the amount of petitioner’s alternative minimum taxable income for purposes of calculating the alternative minimum tax imposed by section 55(a).2 Resolution of the amount of petitioner’s alternative minimum taxable income is dependent upon whether interest paid in 1979 by petitioner with respect to the 1976 purchase of stock is a deduction for purposes of determining the amount of petitioner’s “adjusted itemized deductions,” or whether such interest…
2Cases cited4 opinions
- Commissioner v. LoBueSupreme Court of the United States · 1956
- Commissioner v. National Alfalfa Dehydrating & Milling Co.Supreme Court of the United States · 1974
- Riley v. CommissionerUnited States Tax Court · 1976
- Rhude v. United StatesDistrict Court, D. Minnesota · 1984
3Cited by8 opinions
- Katherine Lynn McCarthy Trust Dated 12/27/76, Lynn McCarthy Successor Trustee v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1987
- Ungerman Revocable Trust v. CommissionerUnited States Tax Court · 1987
- Christman v. CommissionerUnited States Tax Court · 1989
- McCarthy Trust v. CommissionerUnited States Tax Court · 1986
- O'Hagan v. CommissionerUnited States Tax Court · 1995
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