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Background
Petitioner resided in Kihei, Hawaii, at the time he filed
the petition. During 1994, petitioner worked as a self-employed
physical therapist and received nonemployee compensation in the
amount of $41,201.23. Also during 1994, petitioner sold a parcel
of real property for $28,000.
Petitioner did not file a timely 1994 Federal income tax
return and has made no payments regarding his 1994 income tax
liability. On October 16, 1995, petitioner sent a Form 1040NR,
U.S. Nonresident Alien Income Tax Return, to respondent's service
center in Philadelphia, Pennsylvania, which was received on
October 20, 1995. Petitioner's Form 1040NR reported zeros on
most lines, including those for income and tax. Petitioner
altered the jurat and in the space for listing his occupation
stated that he had no occupation within the United States.
On April 18, 1997, respondent mailed a notice of deficiency
to petitioner regarding his 1994 income tax liability.
Petitioner timely filed his petition with this Court on July 16,
1997. Respondent has made no assessment of tax regarding
petitioner's 1994 Federal income tax.
In July 1997, petitioner mailed a Form 1040, U.S. Individual
Income Tax Return, for the taxable year 1994 to respondent's
service center in Fresno, California. Except for amounts
representing a claimed standard deduction and personal exemption,
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