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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 she
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