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We give examples showing that two well-known versions of the S-matrix theory, which describes a nonresonant multiphoton ionization of atoms and ions in intense laser fields, lead to qualitatively different results. The latter refer not only to total ionization rates, but also to energy distributions of photoelectrons, for instance in a polarization plane of the laser field. It should be possible to make an experiment testing predictions of both theories in the near future.

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