John Joseph Vax and Natalie Vax - Page 2

                                        - 2 -                                         
               All section references are to the Internal Revenue Code in             
          effect for the year in issue, and all Rule references are to the            
          Tax Court Rules of Practice and Procedure.  All references to               
          petitioner in the singular are to petitioner John Joseph Vax.               
               The issue for decision is whether respondent’s calculation             
          of petitioners’ alternative minimum tax (AMT) liability for 2000            
          would violate a treaty between the United States and the Czech              
          Republic.                                                                   

          Background                                                                  
               The facts of this case were submitted fully stipulated under           
          Rule 122 and are so found.                                                  
               Petitioner is a citizen of the United States, and petitioner           
          Natalie Vax is a citizen of the Czech Republic.                             
               During 2000 and at the time the petition was filed,                    
          petitioners resided and worked in the Czech Republic.                       
               During 2000, petitioner earned US$199,974 from his                     
          employment with a Czech bank, on which income petitioner paid               
          US$62,738 in income tax to the Czech Republic.                              
               On October 15, 2001, petitioners untimely filed their 2000             
          joint U.S. Federal income tax return, which was dated June 1,               
          2001.  On their 2000 tax return, petitioners reported the                   
          $199,974 petitioner received from the Czech bank, and petitioners           
          claimed a $70,809 foreign earned income exclusion, a $2,000 IRA             
          deduction, a $7,350 standard deduction for married individuals              





Page:  Previous  1  2  3  4  5  6  7  8  Next

Last modified: May 25, 2011