- 2 - Addition to Tax Year Deficiency Sec. 6654 1993 $15,511 $651 1994 62,745 3,232 All section references are to the Internal Revenue Code in effect for the years in issue. The primary issue we must resolve is whether petitioner, an Argentinean citizen, is subject to U.S. tax on compensation he received during 1993 and 1994. Resolution of this issue requires us to decide whether during 1993 and 1994 petitioner was a “resident alien”, as that term is defined in section 7701(b)(1)(A), which in turn requires us to determine whether petitioner meets the “substantial presence test” of section 7701(b)(3) for those years. If petitioner is subject to U.S. tax on the compensation he received during 1993 and 1994, we then must resolve whether petitioner is liable for the section 6654 addition to tax (failure to pay estimated income tax) for 1993 and 1994. FINDINGS OF FACT Some of the facts have been stipulated and are so found. The stipulation of facts and the attached exhibits are incorporated herein by this reference. Background Petitioner’s mailing address was in Buenos Aires, Argentina, at the time he filed his petition contesting respondent’s determination.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
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