- 6 -
his country as "Arkansas and the States united with it by and
under the Constitution of the USA". The Forms 1040NR contained
the word "NONE" or character "N/A" in pertinent spaces for
income, deductions, taxes owed, and payments. On the return,
petitioner reported that he was not a U.S. citizen. As part of
the return, petitioner attached a statement to each form that
reported that he was "a domiciled inhabitant of an American
State" and that his "tax home was within an American Union
State". Petitioner reported that he did not receive any gross
income effectively connected to a U.S. trade or business. He
further reported that he had American earned income of
approximately $65,000 which was foreign gross income excludable
and exempt from U.S. taxation under section 911(a)(1).
On August 30, 1994, respondent mailed a notice of deficiency
to petitioner. Respondent determined that petitioner did not
file valid tax returns for each of the years in issue. After he
received the notice of deficiency, petitioner submitted a second
set of Forms 1040NR for taxable years 1990, 1991, and 1992, dated
November 15, 1994. Petitioner provided his name and Social
Security number on the forms and signed each of them. As a part
of the address, petitioner identified his country as "Arkansas,
USA". The second set of Forms 1040NR contained "NONE" or "N/A"
in pertinent spaces. On line 23 of the forms, petitioner
reported that he received $65,000 in income that was exempt from
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011