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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, petitioner
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