- 3 -
FINDINGS OF FACT
Some facts have been stipulated and are so found. The
stipulation of facts and attached exhibits are incorporated
herein by this reference.
Background
Petitioner resided in Belgium at the time the petition was
filed.
Petitioner was born in The Netherlands in 1932. He is not a
U.S. citizen. Petitioner came to the United States in 1987 and
resided here during 1987 and 1988. In 1989, petitioner did not
reside in the United States.
Petitioner’s Returns
For both 1987 and 1988, petitioner made returns of Federal
income tax on Form 1040, “U.S. Individual Income Tax Return” (the
1987 and 1988 returns, respectively). For 1989, petitioner made
a return of Federal income tax on Form 1040NR, “U.S. Nonresident
Alien Income Tax Return” (the 1989 return). Petitioner filed the
1989 return on May 29, 1990.
Notice of Deficiency
Respondent’s notice of deficiency (the notice) is dated
May 22, 1996.
Ampel Notes; Floridama Note
Petitioner began investing in real property in the United
States in 1968. Between 1976 and 1984, he acquired at least
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011