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petitioner reduced his U.S. tax liability to zero by applying a
$42,991 foreign tax credit.
Respondent examined petitioner's 1995 return and determined
that petitioner had negligently failed to report that he owed the
AMT. Respondent determined that petitioner owed $3,893 in AMT
after allowing a foreign tax credit, as permitted by section 59.
Respondent also determined a $778.60 penalty for negligence for
failing to report and pay the AMT and that petitioner was liable
for a $194.65 late filing addition to tax because his return was
received and filed after the required date.
OPINION
Alternative Minimum Tax
As a nonresident U.S. citizen, petitioner was required to
file Federal income tax returns and report his worldwide income.
See sec. 6012; sec. 1.6012-1(a)(1)(i), Income Tax Regs. He was
entitled to claim a foreign tax credit each year for income tax
paid to foreign jurisdictions. See secs. 27(a), 901. Using
these foreign tax credits, petitioner reduced his regular Federal
income tax liability to zero. He did not report, however, any
liability for the section 55 AMT.
Section 55(a) imposes an AMT on noncorporate taxpayers equal
to the excess of the "tentative minimum tax" over the "regular
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