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filing a joint return, and $5,600 in personal exemptions, and on
which tax return petitioners reported $114,215 in taxable income
and a tax liability of $26,871.
Also, on petitioners’ 2000 joint Federal income tax return,
the $62,738 in income taxes that petitioners in 2000 paid to the
Czech Republic was claimed as a foreign tax credit that fully
offset petitioners’ reported $26,871 U.S. Federal income tax
liability, reducing petitioners’ $26,871 postcredit U.S. income
tax liability to zero.
On their joint U.S. Federal income tax return for 2000,
petitioners did not calculate, nor report, any AMT liability.
In a notice of deficiency issued on November 15, 2002,
respondent determined that petitioners, for 2000, were subject to
an AMT liability in the amount of $2,136 with respect to
petitioners’ 2000 taxable income and that petitioners were liable
for an addition to tax under section 6651(a)(1) for failure to
timely file their 2000 Federal income tax return.
Discussion
Under section 6012, taxpayers, including nonresident U.S.
citizens, are required to file U.S. Federal income tax returns
and to report and calculate their regular Federal income tax
based on their worldwide income. See sec. 6012(a), (c); sec.
1.6012-1(a)(1)(i), Income Tax Regs.
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