Ronald M. Brooke - Page 2




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          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 and           






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