- 4 - those years in the following amounts: Year Wages 1984 $52,500 1985 57,300 1986 58,526 1987 87,645 1988 111,350 Attached to each of the returns for 1984 through 1988 were documents entitled "Statements" and "Declarations" of petitioner in which, among other things, he asserted that the wages that he received were not taxable income and that he was a nonresident alien. At or very shortly before the time petitioner filed returns for 1984 through 1988 with the Austin Service Center, he filed a Form 1040NR (U.S. Nonresident Alien Income Tax Return) for each of those years with the Internal Revenue Service Center in Philadelphia, Pennsylvania, in which he reasserted his claim that he was a nonresident alien and that he owed no taxes to the United States. During each of the years at issue, petitioner, who was licensed as a certified public accountant by the State of Ari- zona, was employed by Dixon Properties, Inc. and/or Dixon International Holdings (U.S.A.), Inc. (Dixon) as vice president in charge of finance and corporate comptroller. The major source of income for petitioner during the years 1983 through 1988 was Dixon. In his capacity as financial officer of Dixon, petitionerPage: Previous 1 2 3 4 5 6 7 8 9 Next
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