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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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