Paul J. Pekar - Page 16




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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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