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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
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Last modified: May 25, 2011