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.
- Decided 10/16/2009
- Published 10/16/2009
- Before: ROGERS and KAVANAUGH, Circuit Judges, and WILLIAMS, Senior Circuit Judge.
- 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.