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Patty, a single taxpayer, has $100,000 of U. S. source taxable income and $300,000 of foreign source taxable income from countries X and Y for a total worldwide taxable income of $400,000. Countries X and Y levy a total of $89,000 in foreign taxes upon the foreign source taxable income. U. S. taxes before credits are $115,194. The foreign tax credit limitation is

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