Pekar v. Commissioner
United States Tax Court
P, a U.S. citizen, resided in Germany and the United Kingdom during his 1995 tax year. He paid resident income tax to the foreign countries in an amount exceeding his reported U.S. income tax liability. P claimed a foreign tax credit that reduced his U.S. income tax to zero. P did not compute or report liability for the alternative minimum tax (AMT) under sec. 55, I.R.C., or the foreign tax credit limitations under sec. 59, I.R.C.
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P, a U.S. citizen, resided in Germany and the United Kingdom during his 1995 tax year. He paid resident income tax to the foreign countries in an amount exceeding his reported U.S. income tax liability. P claimed a foreign tax credit that reduced his U.S. income tax to zero. P did not compute or report liability for the alternative minimum tax (AMT) under sec. 55, I.R.C., or the foreign tax credit limitations under sec. 59, I.R.C. P claimed that the sec. 59, I.R.C., limit on foreign tax credits violated the double taxation prohibitions of the U.S. income tax treaties with Germany and the…
1Opinion of the Court
PAUL J. PEKAR, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Pekar v. Commissioner
No. 15289-97
United States Tax Court
113 T.C. 158; 1999 U.S. Tax Ct. LEXIS 39; 113 T.C. No. 12;
September 1, 1999, Filed
Decision will be entered under Rule 155.
P, a U.S. citizen, resided in Germany and the United
Kingdom during his 1995 tax year. He paid resident income tax to
the foreign countries in an amount exceeding his reported U.S.
income tax liability. P claimed a foreign tax credit that
reduced his U.S. income tax to zero. P did not compute or report
liability for the alternative minimum tax (AMT)…
2Cases cited19 opinions
- United States v. Skelly Oil Co.Supreme Court of the United States · 1969
- Ronald L. Lerch and Dalene Lerch v. Commissioner of Internal Revenue ServiceCourt of Appeals for the Seventh Circuit · 1989
- Kolom v. Comm'rUnited States Tax Court · 1978
- Union Equity Cooperative Exchange v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1973
- Union Equity Cooperative Exchange v. CommissionerUnited States Tax Court · 1972
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