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attached exhibits. At the time of filing the petition,
petitioner resided in San Gabriel, California.
Petitioner was born in China in 1950 and came to the United
States in 1970. Petitioner received a bachelor of science degree
in engineering in the United States and, after graduation, took
graduate courses in business and corporate finance.
In 1986, petitioner commenced employment with Varian
Associates, Inc. (Varian), in Palo Alto, California.
Petitioner's 1990 Federal income tax return correctly lists his
W-2 wage income for the 1990 taxable year from Varian as $35,181,
from which amounts were withheld for Federal income tax purposes.
In the fall of 1990, petitioner moved from San Francisco to
Los Angeles where he remained for approximately 3 weeks before
moving to Hong Kong. Petitioner arrived in Hong Kong on November
28, 1990. Petitioner did not move to Hong Kong in connection
with a job transfer or to accept new employment and did not
become an employee of any business while in Hong Kong. At the
time petitioner moved to Hong Kong, he intended to start a
business of his own, although he did not have specific plans to
start any particular business. On his 1990 Federal income tax
return, petitioner claimed a deduction for moving expenses in
connection with the moves to Los Angeles and to Hong Kong in the
amount of $3,184, of which $500 was estimated as the cost of his
move to Los Angeles.
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