Paul J. Pekar - Page 3




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          Over the years, he worked in Europe and the Middle East, residing           
          at job locations.  In 1995, petitioner lived and worked in the              
          United Kingdom and in Germany.  While in Germany, petitioner was            
          the chief financial officer for Conoco.                                     
               During his absence from the United States, petitioner paid             
          income tax to his respective resident countries and continued to            
          report his income to the Internal Revenue Service (IRS).                    
          However, petitioner did not report that he was subject to the               
          AMT.  Respondent audited petitioner's 1991 return and determined            
          that petitioner had failed to report or pay the AMT.  During                
          January 1995, petitioner conceded the 1991 AMT issue, which he              
          had disputed in a petition to this Court.  In that proceeding, we           
          entered the parties' stipulated decision.  At the time he filed             
          his 1995 return, petitioner had agreed that he owed the AMT for             
          1991 but he chose not to report AMT liability for 1995.                     
               In 1995, petitioner reported $253,077 gross income and                 
          $169,275 adjusted gross income.  He claimed a $5,750 standard               
          deduction in a head of household filing status, personal                    
          exemptions for himself and his sons totaling $7,926, a foreign              
          earned income exclusion of $70,000, and a housing exclusion of              
          $15,474.  He reported $155,599 taxable income and $42,991 tax.              
          Stating that he had lived in and paid resident income taxes to              
          Germany and the United Kingdom for the entire tax year,                     






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