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Canadian law concerning residence. In the absence of any evidence
regarding the Canadian law for determining residence for income tax
purposes, we conclude that Victor, Jr. was not a Canadian resident
for income tax purposes in 1990. See MacLean v. Commissioner, 73
T.C. 1045, 1053 (1980) (petitioner not considered a resident of the
United Kingdom where he failed to cite any United Kingdom statutory
or case law authority); Afshar v. Commissioner, T.C. Memo. 1981-241
("where neither party has offered any material with respect to the
applicable foreign law, we need not take judicial notice of such
law"), affd. without published opinion 692 F.2d 751 (4th Cir. 1982).
Accordingly, the "tie-breaker" rules of the treaty are inapplicable.
Consequently, we hold that Victor, Jr. is a resident of the United
States for 1990 pursuant to section 7701(b)(1)(A)(i).
VII. Issue 6: Additions to Tax and Penalties
FINDINGS OF FACT
Respondent determined additions to tax for negligence under
section 6653(a)(1)(A) and (B), additions to tax for negligence under
section 6653(a)(1), additions to tax for substantial understatements
under section 6661(a), and accuracy-related penalties for negligence
or substantial understatements under section 6662(a). Respondent
also determined additions to tax for failure to file tax returns
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