Robert M. and Pamela Price - Page 3




                                        - 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 she                 






Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  Next

Last modified: May 25, 2011