Michael James Heun - Page 4

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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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