- 8 - 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 taxPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011