Katherine Lynn McCarthy Trust Dated 12/27/76, Lynn McCarthy Successor Trustee v. Commissioner of Internal Revenue

BOOCHEVER, Circuit Judge:

The Katherine Lynn McCarthy Trust (trust or taxpayer) appeals the tax court’s deficiency judgment entered against it for the taxable year 1979 in the amount of $10,506, 86 T.C. 781. The trust concedes that it was subject to the alternative minimum tax under I.R.C. § 55(a) (1979), but contends that for the purpose of this section its interest income and interest expense should be netted to determine its adjusted gross income. Because the trust’s interest income exceeded its interest expense, this computation, if allowed, would eliminate the interest expense from being…