Jose Angel Lujan - Page 8




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         Argentinean Activities                                                         
              At all relevant times, petitioner maintained an Argentinean               
         driver’s license.  Beginning in July 1993, he served as an adviser             
         to the Argentinean military and was active in several Argentinean              
         political groups.                                                              
         Absence of Filing 1993 and 1994 Tax Returns                                    
              Petitioner did not file U.S. or Argentinean income tax returns            
         for 1993 or 1994.  Moreover, he did not pay any U.S. estimated                 
         income taxes for these years.                                                  
         Notice of Deficiency                                                           
              In the notice of deficiency, respondent determined that                   
         petitioner was a resident alien for 1993 and 1994, which required              
         him to file U.S. income tax returns for those years, reflecting the            
         compensation he received ($50,000 for 1993 and $180,000 for 1994).             
         Respondent further determined that for both years, petitioner was              
         liable for the section 6654(a) addition to tax for failure to pay              
         estimated income tax.                                                          
                                       OPINION                                          
              In general, all U.S. citizens, wherever resident, and all                 
         resident alien individuals (citizens of a foreign country), are                
         liable for income taxes imposed by the Internal Revenue Code,                  
         whether the income received is from sources within or without the              
         United States.  See sec. 1.1-1(b), Income Tax Regs.  An individual             
         is a nonresident alien, and generally not subject to U.S. income tax           







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