Research Problem 3. Stuart is a columnist for a metropolitan newspaper. He has a degree in journalism from a major midwestern university.

For the past 10 years, Stuart has prepared his own income tax returns. He finds doing so to be challenging and stimulating and believes that he pays lower taxes than he would if he hired a tax return preparer.

His 2011 return is audited. Although it included an AMT form (Form 6251), Stuart had not prepared it properly. Data from his Form 1040 were transferred to the wrong line in several places. In other cases, positive adjustments were not included because Stuart had failed to calculate them (e.g., he did not recalculate itemized deductions for AMT purposes and did not have a positive adjustment for the personal exemption). Based on the IRS’s calculation, a deficiency of $3,000 was assessed. Stuart’s response to the IRS is that Form 6251 is ambiguous and misleading and, therefore, he should not be liable for the AMT. Evaluate Stuart’s argument.

Partial list of research aids:

William M. Christine, 66 TCM 1025, T.C.Memo. 1993–473.