- 3 - the alternative minimum tax net operating loss deduction. Petitioner claimed on his U.S. income tax return that the foreign tax credit and net operating loss deduction completely offset any U.S. tax liability he may have had for 1992. Petitioner’s 1992 Federal income tax return was received by respondent on April 15, 1996. Respondent later reviewed petitioner’s 1992 return and determined that petitioner had negligently failed to report that he owed the AMT. Respondent determined that petitioner owed $12,186 in income tax after the correct foreign tax credit was applied and a negligence penalty of $2,437.20 for failing to report and pay his AMT. Respondent also determined that petitioner owed a late-filing addition of $3,046.50 because his return was received after the required date for foreign returns. OPINION Nonresident U.S. citizens, such as petitioner, are required to file Federal income tax returns by a date certain and report all worldwide income. See sec. 6012; sec. 1.6012-1(a)(1)(i), Income Tax Regs. If the nonresident citizen pays income tax to foreign jurisdictions, that citizen is entitled to claim a foreign tax credit. See secs. 27(a), 901. Petitioner received U.S.-source income, in the form of dividends and interest, and German-source income, in the form of a salary from his company based in Germany. He reported all sources of income on hisPage: Previous 1 2 3 4 5 6 7 8 Next
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