- 22 - otherwise compensated therefor), the payments constitute dividends from a foreign source received by DPP on behalf of the shareholder-partners. Based then on the above characterizations as foreign source income, petitioners assert that they are entitled to foreign tax credits for the taxes paid to the Israeli Government on the special commissions and that both types of payments are to be included in calculating the amount of the credits. In the alternative, if the claimed credits are reduced or disallowed, petitioners seek a deduction for foreign taxes paid. Lastly, petitioners dispute application of the section 6662(a) penalty on the grounds that they acted reasonably and in good faith in relying on a professional tax adviser, with respect to complex matters. B. Respondent’s Position Conversely, respondent asserts that petitioners’ characterizations impermissibly seek to reduce U.S. income taxes through improper claiming of foreign tax credits and assigning of income among entities. Concerning the special commissions, respondent maintains that petitioners should not be permitted to depart from the position repeatedly taken for both U.S. and Israeli reporting purposes that the amounts represented compensation for services. Moreover, since no recipientPage: Previous 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 Next
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