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United States DC Circuit

Jamieson v. Comm'r of Internal Rev. Serv., 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 supercede any preexisting treaty obligation with which it conflicted.

Appellate Information

  • Decided 10/16/2009
  • Published 10/16/2009


  • Before:  ROGERS and KAVANAUGH, Circuit Judges, and WILLIAMS, Senior Circuit Judge.


  • United States DC Circuit


  • For Appellant:
  • William David Jamieson and Judith A. Jamieson, pro se, were on the briefs for appellants.

  • For Appellees:
  • Robert W. Metzler and Melissa Briggs, Attorneys, U.S. Department of Justice, were on the brief for appellee.  John A. Nolet, Attorney, entered an appearance.
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