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his credit card for 160 days in Florida and for 55 days in other
locations in the United States.
For the 1990 taxable year, Victor, Jr. filed a Canadian
resident income tax return. For the 1991 taxable year, Victor, Jr.
claimed that he was a United States resident for income tax purposes
and resided in Fort Lauderdale, Florida.
During 1990, Victor, Jr. also held a Quebec driver's license
and belonged to a health club in Montreal. He owned two automobiles
which were registered in Montreal and garaged at his parents' home.
Many of his personal belongings remained in his parents' home. He
maintained bank accounts at four Montreal banks in 1990. During
1990, he also received personal services from a doctor, a dentist, a
hairdresser, and a tailor in Montreal.
OPINION
For purposes of the Federal income tax, an alien individual
will be treated as a resident alien of the United States with
respect to any calendar year if, at any time during such calendar
year, the individual is a lawful permanent resident of the United
States. Sec. 7701(b)(1)(A)(i); sec. 301.7701(b)-1(b)(1), Proced. &
Admin. Regs. An individual is a lawful permanent resident of the
United States at any time if (1) the individual has the status of
having been lawfully accorded the privilege of permanently residing
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