- 2 - subject to the alternative minimum tax (AMT), and whether he was negligent when he failed to calculate the AMT on his 1992 Federal income tax return. Petitioner also challenges the late-filing penalty determined by respondent. FINDINGS OF FACT The stipulation of facts and the exhibits attached thereto are incorporated herein by this reference. At the time his petition was filed, petitioner was a U.S. citizen residing in Ludwigshafen, Germany. Petitioner had remained in Germany after retiring from the U.S. Army in 1985. From 1986 to 1992, petitioner owned a business that contracted with the U.S. military in Germany. In 1992, he received $567,331 in income from that business and reported an adjusted gross income of $507,761. Included in that amount was interest income of $1,421 and dividend income of $196, both of which are considered U.S.-source income and were not taxed by the German Government. Petitioner paid 456,738 German marks (DM) for taxes associated with the 1992 taxable year to the German Finanzamt, the sovereign taxing authority of Germany. Using the applicable exchange rate for that time (DM 1.56 to the dollar), that amount equals $292,781. The parties agree that petitioner’s U.S. tentative AMT liability for 1992 would have been $121,863 before accounting for the alternative minimum tax foreign tax credit andPage: Previous 1 2 3 4 5 6 7 8 Next
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