Sparrow v. Commissioner
United States Tax Court
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
William W. Sparrow and Lydia S. Sparrow, Petitioners v. Commissioner of Internal Revenue, Respondent
Sparrow v. Commissioner
Docket No. 17238-83
United States Tax Court
86 T.C. 929; 1986 U.S. Tax Ct. LEXIS 111; 86 T.C. No. 55;
May 5, 1986, Filed
Decision will be entered for the respondent.
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…
2Cases cited6 opinions
- Badaracco v. CommissionerSupreme Court of the United States · 1984
- Greenberg's Express, Inc. v. CommissionerUnited States Tax Court · 1974
- Huntsberry v. CommissionerUnited States Tax Court · 1984
- Warfield v. CommissionerUnited States Tax Court · 1985
- Sparrow v. CommissionerUnited States Tax Court · 1986
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