Jamieson v. Comm'r of Internal Rev. Serv., No. 08-1253

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