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as it applied to Americans living abroad through a seminar and
that he had engaged in many discussions with other American
expatriates about the AMT. Petitioner's experience had given him
a basic understanding of the AMT. He cannot reasonably claim
that he did not know that he could be subject to the tax.
Furthermore, as we noted in Jamieson v. Commissioner, T.C. Memo.
1995-550, Lindsey v. Commissioner, 98 T.C. 672 (1992), had been
decided by our Court and affirmed by the Court of Appeals by the
time petitioner filed his 1995 return. Therefore, petitioner was
on notice that the AMT foreign tax credit claimed by him was
calculated improperly. See Jamieson v. Commissioner, supra.
Moreover, we note that petitioner failed to make any reference to
the AMT or to disclose his views on his return.
We also consider petitioner's educational background in
determining whether he acted reasonably under the circumstances.
See Vick v. Commissioner, T.C. Memo. 1984-353. Petitioner was
the chief financial officer for Conoco in Germany and had general
economic and financial knowledge. Under these circumstances, we
hold that petitioner acted negligently when he failed to
calculate and report the AMT due on his 1995 return.
Late-Filing Addition
Individual Federal income tax returns are generally due on
or before April 15 of the year following the close of the
calendar year. See sec. 6072(a). However, there are exceptions
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