- 3 - The parties agree that, if the Court finds that petitioners' alternative minimum tax foreign tax credit is subject to limitation under section 59(a)(2), then the deficiency in petitioners' Federal income taxes for 1998 is $50,200. They further agree that, if the Court finds that petitioners' alternative minimum tax foreign tax credit is not limited by section 59(a)(2), then no deficiency exists in petitioners' income tax for 1998. The parties submitted this case fully stipulated pursuant to Rule 122 of the Tax Court Rules of Practice and Procedure. The stipulation of facts and accompanying exhibits are incorporated herein by this reference. At the time the petition was filed, petitioners resided in Santa Barbara, California. At all times material to this proceeding, Mr. Price was a citizen of the United States of America and Mrs. Price was a citizen of Canada. They were husband and wife, and they resided in Canada. Throughout 1998, Mr. Price was employed as a stockbroker by Newcrest Capital, Inc., a Canadian corporation, and all of the income that he received during 1998 came from Canadian sources. Mr. Price reported his income on his separate Canadian income tax return, and he paid income taxes to Canada. Mrs. Price was not employed during 1998 and shePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011