In an appeal from the Tax Court’s determination that the taxpayers owed alternative minimum tax (AMT), the order is affirmed where the Technical and Miscellaneous Revenue Act of 1988 made it crystal clear that Congress intended the 90% cap on the AMT foreign tax credit to supersede any preexisting treaty obligation with which it conflicted.
Read Jamieson v. Comm’r of Internal Rev. Serv., No. 08-1253
Appellate Information
Decided October 16, 2009
Judges
Opinion by Judge Williams
Counsel
For Appellants:
William David Jamieson and Judith A. Jamieson, pro se.
For Appellee:
Robert W. Metzler and Melissa Briggs, Attorneys, U.S. Department of Justice, Washington, DC
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