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By separate notices of deficiency, respondent determined the
following deficiencies in and additions to petitioners' Federal
income taxes:
Additions to Tax
Year Deficiency Sec. 6651(a)(1) Sec.6653(a)(1)
1986 $1,998 $499.50 $99.90
1987 1,794 449.00 90.00
Following concessions by the parties,2 the issues for
decision for the year 1987 are: (1) Whether petitioners are
subject to the application of section 59(a)(2), which limits the
amount of the alternative minimum tax foreign tax credit
otherwise allowable under section 59(a)(1), and (2) whether
petitioners are liable for the additions to tax under sections
6651(a)(1) and 6653(a)(1).
Some of the facts were stipulated, and those facts, with the
annexed exhibits, are so found and are incorporated herein by
reference. At the time the petition was filed, petitioners'
legal residence was Saint John, New Brunswick, Canada.
Petitioners, nonresident United States citizens, have
resided in Canada since 1979. William David Jamieson
2 In their pleadings, petitioners alleged that respondent was
barred from assessing and collecting taxes against them for the
years at issue because of the period of limitations under sec.
6501(a). In the answer, respondent denied the allegation and
affirmatively alleged that respondent was not barred. At trial,
petitioners conceded this issue. Also at trial, respondent
conceded the deficiency and additions to tax against petitioners
for 1986.
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