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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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